Faceless assessment limitation turns on ITBA upload date, and the final assessment order was time-barred.

In faceless assessment proceedings, the limitation for passing the final assessment order under section 144C(13) ran from the date the DRP directions were uploaded on the ITBA portal, applying the rules on electronic records under section 13 of the Information Technology Act, 2000 read with section 144B of the Income-tax Act, 1961. The uploaded date was treated as the date of dispatch and receipt, so the statutory period began from the end of that month. On the record, the assessment order passed on 01.07.2022 was issued after the prescribed time, and the final assessment order was therefore barred by limitation and invalid.

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Issues: Whether the final assessment order passed under section 144C(13) was time-barred because the DRP directions were treated as received on the date of upload on the ITBA portal, and whether the assessment completed on 01.07.2022 was within the statutory period.

Analysis: The dispute turned on the point of time when the DRP directions were dispatched and received in the faceless assessment system. Applying the principles governing 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, the relevant date was the date on which the DRP order was uploaded on the ITBA portal. On that basis, the statutory period under section 144C(13) commenced from the end of the month of such upload, and the final assessment order had to be passed within the prescribed time. The record showed that the order was passed after the limitation period had expired.

Conclusion: The final assessment order was held to be barred by limitation and therefore invalid.

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