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CA Final · Direct Tax Laws & International Taxation · Dispute Resolution

A draft assessment order is forwarded to a non-resident eligible assessee, Orion Ltd (a foreign company), on 18 August 2026. Orion files objections within time. By what date must the Dispute Resolution Panel issue its directions under section 275(13)?

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

  1. A31 May 2027Correct
  2. B30 April 2027
  3. C18 May 2027
  4. D31 August 2027

Explanation

Under section 275(13), no direction may be issued after nine months from the end of the month in which the draft order is forwarded. The month of forwarding is August 2026, which ends on 31 August 2026. Nine months from that date is 31 May 2027. The option of 18 May 2027 wrongly counts from the actual date of forwarding instead of the end of the month.

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