Allowing the petition the Court held that failure to follow procedure is  not merely procedural irregularity but illegality. Final order passed two years after receipt of  directions from Dispute Resolution Panel Assessment order time-barred. Original return of  income to be accepted.  Direction to refund excess of  legitimate tax. Referred  Shell India Markets Pvt Ltd  v. Addl. CIT (2022) 443 ITR 366 (Bom)(HC), Turner International India Pvt Ltd v. Dy. CIT (2017) 398 ITR 177 (Delhi)(HC), Vodafone Idea Ltd v. ACIT (2020) 424 ITR  664 (SC) .Court also observed as under . “  we strongly recommend that a detailed enquiry be initiated on the failure on the part of the Faceless Assessing Officer concerned to act in accordance with the provisions of the Act and the lack of diligence on the part of officials concerned and the system itself insofar as it relates to the present assessment. Strict action should be taken against persons responsible for the laxity and lethargy displayed which has caused a huge loss to the exchequer and in turn to the citizens of this country. A copy of this order be circulated to the CBDT and the Principal Secretary, Ministry of Finance, GOI.”    (AY.2016-17)