Faceless assessment limitation starts when DRP directions are uploaded to the portal and received electronically.

In a faceless assessment regime, DRP directions uploaded on the departmental portal were treated as received when they entered the department's computer resource, so limitation under section 144C(13) of the Income-tax Act ran from that date. Reading the statutory phrase "upon receipt" with section 13 of the Information Technology Act, 2000 and paragraph 10 of the E-Assessment Scheme, 2019, the Court held that electronic dispatch and receipt are complete once the record is uploaded and outside the originator's control. On that basis, the assessment orders passed later were beyond limitation and were set aside.

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Issues: Whether the limitation period under section 144C(13) of the Income-tax Act, 1961 for passing the final assessment order commenced on 30.06.2022, when the DRP directions were uploaded on the portal, or only on 05.07.2022, when the department claimed actual receipt.

Analysis: The statutory scheme requires the Assessing Officer to complete the assessment within one month from the end of the month in which the DRP directions are received. The expression "upon receipt" was read in the light of section 13 of the Information Technology Act, 2000 and paragraph 10 of the E-Assessment Scheme, 2019, both of which govern despatch and receipt of electronic records. Once the DRP directions were uploaded on the departmental portal on 30.06.2022, they were outside the control of the originator and entered the computer resource of the department, which constituted receipt for the recipient side of the faceless assessment system. The Court also relied on the uniform view taken by other High Courts that portal upload of the DRP directions is sufficient to start limitation under section 144C(13).

Conclusion: The DRP directions were received on 30.06.2022, so the assessment orders dated 30.08.2022 and 01.09.2022 were beyond limitation and liable to be set aside.

Final Conclusion: The writ petitions succeeded and the impugned assessment orders were invalidated on the ground of limitation, with no order as to costs.

Ratio Decidendi: In a faceless assessment regime, uploaded DRP directions constitute receipt when they enter the departmental computer resource, and limitation under section 144C(13) runs from that date.

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