Final Assessment Ignoring DRP Directions Held Void; No Post-Limitation Cure Permissible

Spectro Analytical Labs Private Limited Vs AU Income Tax Department (ITAT Delhi) The assessee challenged the final assessment order for AY 2021-22 on the ground that it was passed without giving effect to the binding directions of the Dispute Resolution Panel (DRP). Although the DRP had issued directions granting partial relief, the Assessing Officer passed the final order on 28.10.2024 merely repeating the draft assessment because the Transfer Pricing Officer had not yet passed an order giving effect to the DRP directions. The Tribunal held that section 144C creates a mandatory and time-bound...