DRP objections filed on the next working day after a Sunday deadline are timely under Section 10 of the General Clauses Act.

The petitioner challenged a final assessment order for AY 2023–24 and consequential penalty proceedings. A draft assessment order was passed on 13 February 2026.

The 30-day period under Section 144C(2) to file objections before the Dispute Resolution Panel (DRP) expired on 15 March 2026, a Sunday. The petitioner filed its objection in Form 35A on 16 March 2026; the judgment records that the respondent had also issued a notice on 14 March granting time until 16 March to file it.

The Assessing Officer rejected the objection as time-barred and passed a final assessment order without awaiting DRP directions. The Department did not seriously oppose setting aside the assessment and remitting the matter to the DRP.

1. Whether an objection filed with the DRP on 16 March 2026 was within time where the 30-day period under Section 144C(2) expired on Sunday, 15 March 2026

2. Whether the Assessing Officer could pass a final assessment order without the DRP adjudicating the objection filed on 16 March 2026

Section 144C(2) of the Income Tax Act, 1961 allows an eligible assessee 30 days to file objections to a draft assessment order before the DRP. Section 10 of the General Clauses Act, 1897 provides that where the last day of a prescribed period falls on a day when the relevant office is closed, the act may be done on the next day the office is open.

Under Sections 144C(5) and 144C(10), the DRP issues directions that are binding on the Assessing Officer; the procedure under Section 144C is mandatory, and the Assessing Officer cannot finalize the assessment before the prescribed process is completed.

The Court also relied on Vijay Bhai N. Chandrani v. SIT, 440 ITR 178, regarding the binding effect of DRP directions.

Because the 30-day deadline fell on a Sunday, the Court applied Section 10 of the General Clauses Act and treated 16 March—the next day on which the office was open—as the timely filing date. The petitioner’s objection was therefore within the prescribed period.

Since a timely objection required the DRP process to be completed, the Assessing Officer could not reject it as late and pass a final assessment order without DRP directions. The resulting assessment order was legally unsustainable.

It quashed and set aside the assessment order and directed the DRP to decide the objection on its merits, after granting the petitioner a personal hearing and within the statutory period.

The consequential penalty proceedings were stayed until the DRP proceedings are disposed of.