The Assessing Officer passed an assessment order under section 144C(13) read with section 143(3) pursuant to the order passed by the DRP. The assessee challenged the validity of order passed by the DRP/Assessing Officer, without a valid DIN generated and quoted in the body of the order in view of Circular No. 19/2019 of CBDT dated 14-8-2019. Allowing the appeal the Court held that, as per section 144C(13), Assessing Officer had to pass final assessment order in conformity with directions issued by DRP and since DRP directions were held as invalid and deemed to have never been issued, being in violation of Circular No. 19/2019, assessment orders passed by Assessing Officer under section 144C(13) read with section 143(3) in pursuant to invalid, non-est DRP directions is bad in law, void ab-initio and accordingly quashed. (AY. 2006-07 to 2020-21)
Sutherland Global Services Inc. v. ACIT (IT) (2024) 205 ITD 270 (Chennai)(Trib)
S. 144C : Reference to dispute resolution panel-Document Identification Number (DIN)-Order passed by DRP without a valid computer-generated Document Identification Number (DIN)-Illegal and non-est and deemed to have never been issued-Assessment order passed by Assessing Officer in pursuance to DRP’s order was bad in law and quashed. [S.144C(13)]