Electronic communication date governs limitation in faceless assessment, making the final assessment order time-barred.

In faceless assessment proceedings, the date of receipt of electronic directions is governed by section 13 of the Information Technology Act, 2000, read with section 144B(6)(v) of the Income-tax Act, 1961. Once the Dispute Resolution Panel's directions are communicated to the designated computer resource, the limitation period under section 144C(13) runs from that communication date, not from a later internal processing date. Applying that principle, the assessment was treated as time-barred because the directions were system-communicated on 30.11.2021 and the final order was passed later. The assessment was quashed on limitation, leaving the merits unexamined.

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Issues: Whether the final assessment order was barred by limitation under section 144C(13) of the Income-tax Act, 1961, because the directions of the Dispute Resolution Panel were communicated to the assessee-side system on 30.11.2021 and the assessment was completed on 31.01.2022.

Analysis: The relevant period under section 144C(13) runs from the end of the month in which the directions are received. In the faceless assessment framework, section 144B(6)(v) directs that the time and place of dispatch and receipt of electronic records be determined in accordance with section 13 of the Information Technology Act, 2000. Applying that rule, the electronic directions are treated as received when they enter the designated computer resource. The record showed issuance and system communication on 30.11.2021, and the assessment could not be sustained by treating the later internal processing date as the starting point for limitation. The Tribunal also treated the case law on issue and communication of notices as supporting the principle that the relevant date is the date of communication or dispatch, not the date of actual physical receipt by the addressee.

Conclusion: The limitation plea was accepted and the assessment order was held to be time-barred.

Final Conclusion: The assessment was quashed on limitation and the merits were left untouched.

Ratio Decidendi: In faceless assessment proceedings, the receipt of electronic directions is governed by section 13 of the Information Technology Act, 2000, and once communicated to the designated computer resource, the statutory period under section 144C(13) of the Income-tax Act, 1961 runs from that communication date, not from a later internal receipt or processing date.

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