Faceless assessment limitation starts with electronic dispatch of DRP directions, not later internal receipt by the assessing unit.

In faceless assessment proceedings, limitation under section 144C(13) of the Income-tax Act starts from the effective electronic dispatch of DRP directions on the portal, read with section 13 of the Information Technology Act and section 144B framework. The Tribunal treated the upload of the directions on the ITBA portal as the ining date for commencement of the limitation period, and held that later internal transmission or physical receipt by the assessment unit did not extend time. As the final assessment order was passed after the prescribed period, it was held time barred and set aside.

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Issues: Whether the final assessment order was barred by limitation under section 144C(13) of the Income-tax Act, 1961, in a faceless assessment where the date of upload/dispatch of the DRP directions on the ITBA portal differed from the date on which the assessment unit asserted receipt of those directions.

Analysis: The Tribunal applied the principle governing dispatch and receipt of electronic records under section 13 of the Information Technology Act, 2000, read with the faceless assessment framework under section 144B of the Income-tax Act, 1961. On the facts, the decisive date was the upload of the DRP directions on the portal, which fixed the commencement of the limitation period under section 144C(13). The later internal transmission or physical receipt by the assessment unit did not extend the statutory time limit. Since the final assessment order was passed after the prescribed period, it was held to be time barred.

Conclusion: The assessment order was invalid as being passed beyond limitation and was set aside.

Final Conclusion: The assessee succeeded on the limitation issue, and the assessment was annulled as time barred; the remaining grounds were rendered academic.

Ratio Decidendi: In faceless assessment proceedings, the limitation under section 144C(13) begins from the effective electronic dispatch of the DRP directions on the portal, and not from any later administrative receipt by the assessing unit.

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