DRP Timeline Breach

In a strict enforcement of procedural timelines, the Court reaffirmed that compliance with Section 144C is mandatory, not directory. It held that once DRP directions are issued, the Assessing Officer is bound to pass the final order within the prescribed period, failing which the assessment lapses automatically. 

The decision underscores that extensions granted under special statutes (like COVID relaxations) do not dilute the ultimate limitation boundary. By relying on settled precedent, the Court emphasized that procedural discipline is integral to jurisdiction, delay is not a curable defect but a fatal one. The ruling is a strong precedent in transfer pricing cases where DRP timelines are breached.