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TMI BlogDecoding the Mandatory Timelines: A Thorough Examination of the Income Tax Assessment Order NullificationX X X X Extracts X X X X X X X X Extracts X X X X ..... also reinforces the legal principles governing the assessment procedure and the role of the Dispute Resolution Panel (DRP). Arguments Presented The primary challenge advanced by the writ petitioner was that the impugned assessment order, dated August 24, 2022, was contrary to the provisions of Section 144C(13) of the Act. The petitioner contended that once the DRP framed its direction on June 20, 2022, in accordance with Section 144C(5) of the Act, the Assessing Officer (AO) was mandated to complete the assessment in conformity with those directions within one month from the end of the month in which such direction was received. The petitioner argued that the DRP's direction was uploaded on the Income Tax Business Application (ITBA) por ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Pricing Officer (TPO) The court noted that the procedure of assessment u/s 144C did not envisage or contemplate the involvement of the TPO once the DRP had framed its direction. The role of the TPO came to an end once an order u/s 92CA(4) of the Act was framed and remitted to the AO. Therefore, there was no occasion for the TPO to resume proceedings after the DRP's direction on June 20, 2022. Faceless Assessment Scheme and Service of Orders The court highlighted the provisions of the E-Assessment Scheme, 2019 , which mandated that all orders, notices, and decisions be uploaded on the ITBA portal as part of the faceless assessment regime. The uploading of the DRP's directive on the ITBA portal on June 24, 2022, constituted valid and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ss Assessment Regime: The judgment highlighted the significance of the E-Assessment Scheme, 2019 , and the requirement of uploading all orders, notices, and decisions on the ITBA portal as part of the faceless assessment regime. Statutory Interpretation: The court applied the principles of statutory interpretation, emphasizing the importance of assigning words their natural, original, and precise meaning when the language of the statute is clear and unambiguous. Comprehensive Summary The judgment provided clarity on the interpretation of Section 144C(13) of the Income Tax Act, 1961 , and reinforced the mandatory nature of the timelines prescribed for completing the assessment after receiving the DRP's directions. The court emphasized th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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