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

A draft order of assessment was forwarded to an eligible assessee in the month of June 2027. The assessee filed objections on time and the Dispute Resolution Panel issued its directions on 12 November 2027. Under the Income-tax Act, 2025, which statement is correct?

The directions are valid because the nine-month limit runs to 31 March 2028, and the Assessing Officer must complete the assessment by 31 December 2027, being one month from the end of November 2027, without giving the assessee any further hearing.

  1. AThe directions are valid and the Assessing Officer must complete the assessment by 31 December 2027, without giving the assessee a further hearingCorrect
  2. BThe directions are invalid as they were issued after nine months from the end of June 2027
  3. CThe directions are valid but the Assessing Officer must give the assessee a fresh opportunity of being heard before completing the assessment
  4. DThe directions are valid and the Assessing Officer must complete the assessment by 30 November 2027, without a further hearing

Explanation

Under section 275(13), directions cannot be issued after nine months from the end of the month in which the draft order is forwarded: nine months from end of June 2027 is 31 March 2028, so 12 November 2027 is in time. Under section 275(14), the Assessing Officer completes the assessment within one month from the end of the month of receipt of directions (November 2027), i.e. by 31 December 2027, with no further hearing. 30 November is wrong because the month in which received is counted to its end and then one month more.

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