TMI Blog2023 (3) TMI 1227X X X X Extracts X X X X X X X X Extracts X X X X ..... mar, Accountant Member : The present appeal has been filed by the assessee against the order dated 30.01.2022 passed by the National Faceless Assessment Centre, Delhi u/s. 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961. 2. The assessee is engaged in the business of providing digital 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 t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... anything contained in section 153 or section 153B, pass the assessment order under sub-section (3) within one month from the end of the month in which,- (a) the acceptance is received; or (b) the period of filing of objections 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 sub-section (5), after considering the following, namely:- (a) draft order; (b) objections filed by the assessee; (c) evidence furnished by the assesse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Assessing Officer. (11) No direction under sub-section (5) shall be issued unless an opportunity of being heard is given to the assessee and the Assessing Officer on such directions which are prejudicial to the interest of the assessee or the interest of the revenue, respectively. (12) No direction under sub-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 be ..... X X X X Extracts X X X X X X X X Extracts X X X X
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