The draft of assessment order was passed on 4-3-2022, but the assessee filed objections before DRP on 6-4-2022. i.e. after due date of time allowed for filing of objections before DRP. On appeal the assessee contended that the final assessment order passed by the AO was invalid, bad in law and liable to be quashed being in contravention of the provisions of section 144C(4) of the Act. The tribunal held that since the final assessment order has been passed after due date prescribed u/s 144C of the Act, the order is barred by limitation and treated as void. (AY. 2013-14)
Mavenir UK Holdings v. ACIT [2024] 205 ITD 1 (Delhi) (Trib)
S. 144C : Reference to dispute resolution panel -Objection is filed before DRP after due date of time allowed for filing objections- AO should carry proceedings to finalize assessment order as per provisions of section -Assessment order was barred by limitation and treated as void. [S.92CA(3), 144C(4), 153]