Fiberhome India Pvt. Ltd. v. NEAC (2022) 444 ITR 237 (Delhi)(HC)

S. 144B : Faceless Assessment-Variation in income-Objections pending disposal before Dispute Resolution Panel-Assessment order set aside. [S. 143(3), 144C(3), Art, 226].

On writ the Court held, that in view of the Central Board of Direct Taxes Circular No. 8 of 2021, dated April 30, 2021 ([2021] 433 ITR (St.) 405), which had extended the time limit for filing of such objections up till May 31, 2021, the objections filed by the assessee before the Dispute Resolution Panel on May 27, 2021 were within the prescribed time and were being heard on the merits by the Dispute Resolution Panel. Therefore, in view of the scheme of section 144C and the decisions of the Calcutta and Bombay High Courts the final assessment order was set aside and the National E-Assessment Centre was to proceed with the assessment complying with the procedures stipulated in section 144C. (AY.  2017-18)