IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘I’: NEW DELHI BEFORE SHRI C.N. PRASAD, JUDICIAL MEMBER AND SHRI M. BALAGANESH, ACCOUNTANT MEMBER ITA No.5848/Del/2024 Assessment Year 2021-22 Assessment Year 2021-22 Assessment Year 2021-22 Assessment Year 2021-22 Assessment Year 2021-22 Assessment Year 2021-22 Assessment Year 2021-22 Assessment Year 2021-22 Assessment Year 2021-22 Assessment Year 2021-22 Assessment Year 2021-22 Assessment Year 2021-22 Assessment Year 2021-22 Assessment Year 2021-22 Date of Hearing 11.12.2025 Date of Pronouncement 28.01.2026

ORDER

PER C.N. PRASAD, JM, This appeal is filed by the assessee against the order for the A.Y. 2021-22.

2. The Ld. Counsel for the assessee at the outset referring to ground No. 1 and 2 of grounds of appeal submitted that the impugned final assessment order dated 28.10.2024 is invalid null and void as the same was passed not in conformity with the directions issued by the Ld. DRP. The Ld. Counsel for the assessee submitted that provision of section 144C prescribes strict timelines for completion of assessment and there is no scope of curative action after that time lapses.

3. The Ld. Counsel for the assessee submits that the asse