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TMI Blog2023 (3) TMI 1492X X X X Extracts X X X X X X X X Extracts X X X X ..... Ms. Shruti Khimta, AR For the Revenue : Sh. Bhaskar Goswami, CIT DR ORDER Per Dr. B. R. R. Kumar, Accountant Member: The present appeal and Stay Application have been filed by the assessee against the order dated 26.03. 2022 passed by the AO u/s 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961. 2. The assessee is engaged in the business of manufacturing telecommunication equipments and providing maintenance and other allied services of telecommunication equipments in India. 3. The pertinent facts for ad judication of the case are as under: Date of filing return 29.11.2017 Date of order of the TPO 22.01.2021 Date of draft order by the AO 03.03.2022 Date of order of the DRP 16.12. 2021 Date of Assessment Order 26.02. 2022 4. We have gone th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s under sub- section (2) expires. (5) The Dispute Resolution Panel shall, in a case where any objection is received under sub- section (2), issue such directions, as it thinks fit, for the guidance of the Assessing Officer to enable him to complete the assessment. (6) The Dispute Resolution Panel shall issue the directions referred to in subsection (5), after considering the following, namely: (a) draft order; (b) objections filed by the assessee; (c) evidence furnished by the assessee; (d) report, if any, of the Assessing Officer, Valuation Officer or Transfer Pricing Officer or any other authority; (e) records relating to the draft order; ( f) evidence collected by, or caused to be collected by, it; and (g) result of any enquiry made by, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... - section (5) shall be issued after nine months from the end of the month in which the draft order is forwarded to the eligible assessee. (13) Upon receipt of the directions issued under sub-section (5 ), the Assessing Officer shall, in conformity with the directions, complete, notwithstanding anything to the contrary contained in section 153 or section 153B, the assessment without providing any further opportunity of being heard to the assessee, with in one month from the end of the month in which such direction is received. (14) The Board may make rules for the purposes of the efficient functioning of the Dispute Resolution Panel and expeditious disposal of the objections filed under sub- section (2) by the eligible assessee. (14A) The pr ..... X X X X Extracts X X X X X X X X Extracts X X X X
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