Held, that under section 144C(13) of the Income-tax Act, 1961,the Assessing Officer is duty-bound to pass the final assessment order within a period of one month from the end of the month in which the directions of the Dispute Resolution Panel were received. The relaxation under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 would not be applicable to assessment orders passed in consequence of directions of the Dispute Resolution Panel. The assessment order dated September 30, 2021 was barred by limitation and without jurisdiction.(AY.2015-16)
Supermax Personal Care Pvt. Ltd. v .Dy. CIT (2023)101 ITR 29 (SN)(Mum)(Trib)
S. 144C : Reference to dispute resolution panel-International Transaction-Limitation-Assessment order passed beyond one month from the end month in which directions of DPR received-Relaxation under TOLA Act not applicable-Assessment order is barred by limitation. [S. 144B 144C(13),147, 148]