Binding Dispute Resolution Panel directions require fresh assessment where the final order relies on a superseded transfer-pricing order.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Dispute Resolution Panel directions bind the Assessing Officer when an eligible assessee files timely objections to a draft assessment order. A bona fide failure to separately intimate the Assessing Officer of those objections, where it causes no advantage or prejudice, does not justify ignoring the Panel's directions. Where the transfer-pricing order forming the sole basis of the final assessment has been revised pursuant to those directions, an assessment based on the superseded order is unsustainable. The final assessment, consequential demand and penalty-initiation notices were set aside, and the assessment was restored for fresh completion in conformity with the Panel's directions and revised transfer-pricing order.....