Rejection Of Belated Objections By DRP Does Not Extend Limitation Of Passing Final Assessment U/s 144(4): Delhi ITAT

The New Delhi ITAT held that rejection of objections by the DRP due to delay confirms the merit of the draft order by the AO but does not extend the time limit for the final assessment order under Section 144(4) of the Income Tax Act. The ITAT emphasized that the DRP's rejection, without giving directions to the assessing officer, does not empower the AO to proceed with the assessment. It clarified that under Section 144C(8), the DRP can confirm, reduce, or enhance proposed variations but cannot set aside variations or direct further enquiry. The case involved the AO's failure to pass the final assessment within the statutory limit after objections were timely filed with the DRP, leading the ITAT to rule that the AO lacked jurisdiction in passing the final order