Faceless assessment limitation runs from electronic upload of DRP directions, not later internal transmission within the department.

In faceless assessment proceedings, receipt of the Dispute Resolution Panel's directions occurs when they are uploaded on the designated electronic system. Applying sections 144C(13), 144B and 130 of the Income-tax Act, read with section 13 of the Information Technology Act, the electronic upload constituted dispatch and receipt on the same date. Internal retention by the National Faceless Assessment Centre and later transmission to the assessment unit did not postpone the statutory start of limitation. The final assessment order was therefore time-barred, and the limitation objection was allowed in favour of the assessee.

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Issues: Whether the final assessment order was barred by limitation under section 144C(13) of the Income-tax Act, 1961, when the Dispute Resolution Panel's directions were uploaded in the faceless assessment system on an earlier date and later transferred internally to the assessment unit.

Analysis: The time limit under section 144C(13) begins from the receipt of the Dispute Resolution Panel's directions. In the faceless assessment framework, communications are routed through the National Faceless Assessment Centre, and the time and place of dispatch and receipt of electronic records are governed by section 13 of the Information Technology Act, 2000. On a combined reading of sections 130 and 144B of the Income-tax Act, 1961 and section 13 of the Information Technology Act, 2000, upload of the directions on the portal constituted dispatch and receipt on the same date. Internal retention by the faceless centre and later transmission to the assessment unit did not extend the statutory period.

Conclusion: The final assessment order was time-barred and the limitation objection was allowed in favour of the assessee.

Ratio Decidendi: In faceless assessment proceedings, receipt of the Dispute Resolution Panel's directions occurs when they are uploaded on the designated electronic system, and the limitation period under section 144C(13) runs from that date, not from any later internal transmission within the department.

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