Section 144C(13) enjoins Assessing Officer to complete assessment ‘in conformity with directions’ issued by DRP, and it would not be open to him to hold giving effect to these directions even if same were found to be prima facie incorrect. Accordingly the assessment order and giving effect to directions of DRP could not be to said to be non-application of mind by Assessing Officer. (AY. 2016-17)
Michael Page International Recruitment (P) Ltd. v. Dy. CIT (2022) 219 DTR 57 / 99 ITR 65 / 220 TTJ 137 / 143 taxmann.com 253 (Mum)(Trib)
S. 144C : Reference to dispute resolution panel-Rectification order-Not barred by limitation-Order was passed within six months from end of month in which original order was passed-It would not be open to Assessing Officer to hold giving effect to these directions even if said directions were found to be prima facie incorrect. [S. 92C,144C(13), R. 10]