Passing of assessment order two years after Dispute Resolution Panel direction is time barred

Vodafone Idea Limited Vs Central Processing Centre (Bombay High Court) Bombay High Court held that assessment order passed by Faceless Assessing Officer (FAO) two years after the Dispute Resolution Panel (DRP) directions, is time barred and cannot be sustained. Facts- The present proceedings emerge from a Return of Income filed by the petitioner for A.Y. 2016–2017. The ROI disclosed a loss of Rs. 47,50,07,95,276/- under the normal provisions of the Act and loss of Rs. 292,80,62,889/- u/s. 115JB of the Act. Thus, there was a claim for a refund of prepaid taxes of Rs. 1128.47 crore, comprising...