Section 144C(13) limitation turns on portal upload as receipt; assessment order held time-barred and invalid.

Section 144C(13) requires the assessment to be completed within one month from the end of the month in which DRP directions are received by the Assessing Officer. In the faceless assessment framework, communication uploaded on the departmental portal was treated as receipt when it entered the recipient's computer resource. As the Revenue produced no contrary material, the upload date was taken as the date of receipt for limitation. On that basis, the assessment order dated 19.07.2024 was found to have been passed beyond the statutory period and was held time-barred and invalid.

---

---

Issues: Whether the assessment order was barred by limitation under section 144C(13) of the Income-tax Act, 1961, on account of the date on which the Dispute Resolution Panel directions were received by the Assessing Officer, and whether electronic transmission through the portal constituted receipt for computing the limitation period.

Analysis: The statutory scheme under section 144C(13) 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 order relied on the principle that in the faceless assessment framework, communication uploaded on the departmental portal constitutes receipt when it enters the recipient's computer resource. The absence of contrary material from the Revenue meant the date of communication of the DRP directions was treated as the date of upload, and the subsequent assessment order was tested against that date for limitation. Applying the jurisdictional precedent on strict compliance with the mandatory time limit, the assessment order dated 19.07.2024 was found to have been passed beyond the permissible period.

Conclusion: The assessment order was held to be time-barred and invalid, and the ground challenging limitation was accepted.

---