The assessee filed an appeal before the Commissioner (Appeals) under section 246A of the Act against the assessment order dated December 24, 2018. The assessment order dated December 24, 2018 passed by the Assessing Officer was received by the assessee only on December 29, 2018. Unaware of the order, the assessee filed its objections before the Dispute Resolution Panel on December 28, 2018. Once the assessee received the assessment order, the assessee informed the Dispute Resolution Panel that the assessment order albeit illegally had already been passed and, therefore, the Dispute Resolution Panel had no locus to proceed with the objections filed. The assessee also informed the Dispute Resolution Panel that it had already filed an appeal before the Commissioner (Appeals) against the assessment order dated December 24, 2018. Notwithstanding this, the Dispute Resolution Panel proceeded to issue directions dated September 16, 2019 based on which another assessment order dated October 31, 2019 was passed. On a writ petition against the directions of the Dispute Resolution Panel and the assessment order dated October 31, 2019. The Court held  that the directions issued by the Dispute Resolution Panel on September 16, 2019 and the consequent assessment order dated October 31, 2019, were liable to be quashed.  Under section 144C of the Income-tax Act, 1961 the Dispute Resolution Panel can give directions only in pending assessment proceedings. Once an assessment order is passed, rightly or wrongly, the assessment proceedings come to an end. Thereafter, the Dispute Resolution Panel would have no power to pass any directions contemplated under sub-section (5) of section 144C .

 The Court also held that a taxing statute must be interpreted strictly. Equity has no place in taxation. While interpreting a taxing statute intendment would have no place. It is axiomatic that a taxation statute has to be interpreted strictly because the State cannot at its whims and fancies burden the citizens without authority of law .In the matter of interpretation of the charging section of a taxation statute, strict rule of interpretation is mandatory and if there are two views possible in the matter of interpretation of a charging section, the one favourable to the assessee has to be applied. There is nothing unjust in the taxpayer escaping if the letter of the law fails to catch him on account of the Legislature’s failure to express itself clearly. (AY. 2015 -16)