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TMI Blog2023 (3) TMI 1227X X X X Extracts X X X X X X X X Extracts X X X X ..... igital enablement platform to digital merchants and mobile operators. 3. The pertinent facts for adjudication of the case are as under: * Date of filing return - 30.11.2017 * Date of order of the TPO - 28.01.2021 * Date of draft order by the AO - 24.03.2021 * Date of order of the DRP - 16.11.2021 * Date of Assessment Order - 30.01.2022 4. The AO at para 4.2 mentions that the ld. DRP passed order on 22.11.2021 and on receipt of the order of the ld. DRP, the DCIT (TP)-1(3)(1), New Delhi vide DIN ITBA/COM/F/17/2021-22/1037852286(1) dated 16.12.2021 has given effect to the direction of the ld. DRP and proposed an adjustment of Rs. 1,32,76,515/- without making any further adjustments in pursuance of the ld. DRP directions. 5. The pr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ceived 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 sub-section (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, or caused to be made by, it. (7) The Dispute Resolution Panel may, before issuing any direc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hich 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, within 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 provisions of this section shall not apply to any assessment or reassessment ..... X X X X Extracts X X X X X X X X Extracts X X X X
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