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

Kiran Metals Ltd, a foreign company, is forwarded a draft order on 14 August 2026 and files objections within time. The Panel hears the matter and issues directions, received by the Assessing Officer on 20 March 2027. Applying section 275 as amended w.e.f. 1-4-2026, which statement is correct?

Directions could be issued up to 31 May 2027, nine months from the end of August 2026. The Assessing Officer must conform to them and complete the assessment by 30 April 2027, one month from the end of March 2027, without a further hearing.

  1. AThe Panel's last permitted date for directions was 31 May 2027, and the Assessing Officer must complete the assessment by 30 April 2027Correct
  2. BThe Panel's last permitted date for directions was 31 March 2027, and the Assessing Officer must complete the assessment by 30 April 2027
  3. CThe Panel's last permitted date for directions was 31 May 2027, and the Assessing Officer must complete the assessment by 31 March 2027
  4. DThe Panel's last permitted date for directions was 31 May 2027, and the Assessing Officer needs a fresh hearing for the assessee before completing

Explanation

Directions cannot be issued after nine months from the end of the month of forwarding: August 2026 ends 31 Aug 2026, plus nine months gives 31 May 2027. The Assessing Officer must complete the assessment within one month from the end of the month of receipt (March 2027), i.e. by 30 April 2027, with no further hearing under section 275(14). Hence options two, three and four are wrong.

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