The DRP issued directions under section 144C(5) on September 21, 2021. As per section 144C(13), the AO was required to complete the assessment in conformity with the Panel’s directions, without providing any further opportunity of hearing to the assessee, within one month from the end of the month in which the directions were received, i.e., on or before October 31, 2021. However, the AO passed the final assessment order only on November 18, 2021, after the TPO had given effect to the Panel’s directions on October 29, 2021. On appeal, the Tribunal held that the final assessment order having been passed beyond the statutory time limit prescribed under section 144C(13), the order was expressly time-barred, and consequently null and void ab initio, and was liable to be quashed. (AY. 2017-18)