Holiday-Day Limitation Computation Preserves Timely Objections and Prevents Final Assessment From Being Issued Without Mandatory Review Directions

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....Limitation computation treats an objection filed on the next working day as timely where the statutory final day falls on a Sunday. Under section 144C, a timely objection requires the Assessing Officer to await binding Dispute Resolution Panel directions before making a final assessment. Rejection of the objection as time-barred led to the final assessment being quashed, with the objection requiring merits-based consideration after hearing the assessee. Consequential penalty proceedings remain stayed until completion of that adjudication.....