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CMA Final · Direct Tax Laws and International Taxation · Assessment Procedure including Dispute Resolution Process

A Dispute Resolution Panel receives objections against a draft order forwarded to a foreign company in the month of August 2026. Counting from the end of the month in which the draft order was forwarded, by when can the Panel issue directions under section 275 at the latest?

The Panel must issue directions by the end of May 2027. Section 275(13) allows nine months from the end of the month in which the draft order is forwarded, and August 2026 plus nine months ends on 31 May 2027.

  1. AEnd of May 2027Correct
  2. BEnd of August 2027
  3. CEnd of November 2026
  4. DEnd of February 2027

Explanation

Section 275(13) bars directions after nine months from the end of the month in which the draft order is forwarded. The month ends on 31 August 2026, and nine months later is 31 May 2027. August 2027 would be a twelve-month count, and the other options are shorter than nine months.

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