Limitation for DRP directions in faceless assessment runs from system availability, making a delayed final order time barred.

Section 144C(13) limitation in faceless assessment runs from the earliest point at which DRP directions are received and available in the system, not from a later internal administrative entry. The Tribunal examined ITBA functionality, affidavits in related proceedings, and the object of section 144C as a strict time-bound dispute resolution mechanism, and applied precedents that treat uploaded directions with generated DIN as accessible to the assessing authority. On that basis, the final assessment order passed beyond the statutory period was held time barred and unsustainable, and the additions made in it were deleted.

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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 Dispute Resolution Panel directions, though digitally signed on 30.06.2022, were treated by the Revenue as received only on 01.07.2022.

Analysis: The Tribunal examined the ITBA functionality, the affidavits filed in related High Court proceedings, and the consistent judicial view that once DRP directions are uploaded and DIN is generated, they are visible and accessible to the assessing authority in the faceless assessment system. It held that limitation under section 144C(13) must run from the earliest point at which the directions are received in the system and cannot depend on internal user functionality or a later administrative entry. The Tribunal also relied on the object of section 144C as a strict time-bound dispute resolution mechanism and applied the binding precedents holding that delay in passing the final order beyond the statutory period renders the assessment invalid.

Conclusion: The final assessment order dated 24.08.2022 was held to be time barred and unsustainable, and the additions made therein were deleted.

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