Held that under section 144C(13) of the Act, the Assessing Officer should have passed the final assessment order, notwithstanding anything to the contrary contained in section 153 or section 153B, within one month from the end of the month in which the directions of the Dispute Resolution Panel are received. The order sheet showed that the Assessing Officer received the documents on December 30, 2021. Under section 144C(13) of the Act, the order should have been passed on or before January 31, 2022, whereas the Assessing Officer had passed the final assessment order on February 2, 2022, which was beyond the time limit. Hence, the order passed by the Assessing Officer was barred by limitation under section 144C(13). The final assessment order was non est in the eyes of law.(AY.2017-18)
Kontoor Brands India P. Ltd. v. ACIT (2022)100 ITR 73 (SN)(Bang) (Trib)
S. 144C : Reference to dispute resolution panel-Limitation-Time-limit for passing final order of assessment-One month from end of month in which directions of Dispute Resolution Panel received by Assessing Officer-Order passed beyond that date-Non est in law. [S. 92CA (3), 144C(13), 153, 153B]