Ms. Sushma Nagaraj, with Mr. Abhinav Palsikar, Advocates

for the Respondents.

CORAM: B. P. COLABAWALLA &

AMIT S. JAMSANDEKAR, JJ.

Judgment Reserved On : 16th September, 2025

Judgment Pronounced On: 10th October, 2025

JUDGMENT (PER Amit Satyavan Jamsandekar, J ).

1. Rule. Rule made returnable forthwith. The Respondents waive service. With the consent of the parties, taken up for final hearing.

2. By the present Petition, filed under Article 226 of the Constitution of India, 1950, the Petitioner is challenging the inaction of the Respondents of not giving effect to the directions dated 19th March 2020 of the Dispute Resolution Panel (“DRP”) and consequently not processing the refund claim of the Petitioner. The directions were given by the DRP to the 1st Respondent under Section 144(C)(5) of the Income Tax Act, 1961 (“the Act”).

3. The main issue raised in the petition is the effect of not completing the assessment within a period of one month from the end of the month in which the Assessing Officer receives such directions from the DRP under Section 144(C) (5) of the Act. According to the Petitioner, if the Assessing Officer fails to complete the assessment within the time frame as prescrib