Limitation for DRP-based assessment orders runs from receipt by the Assessing Officer in the faceless workflow, not mere upload.

For limitation under Section 144C(13) of the Income-tax Act, the relevant date is when the Assessing Officer receives the Dispute Resolution Panel's directions in the faceless assessment workflow, not merely when the directions are uploaded or communicated to another system node. Applying this approach, the directions uploaded on 22.06.2022 but transmitted to the Jurisdictional Assessing Officer on 04.07.2022 were treated as received on the later date, with the result that the assessment order dated 19.08.2022 was within time. The discussion also refers to Section 13 of the Information Technology Act, 2000 on electronic despatch and receipt.

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Issues: Whether the limitation period for passing the assessment order under Section 144C(13) of the Income-tax Act, 1961 had to be reckoned from the date the Dispute Resolution Panel's directions were uploaded and communicated through the ITBA/NFAC system, or from the date on which the Jurisdictional Assessing Officer received them from the National Faceless Assessment Centre.

Analysis: The limitation under Section 144C(13) runs from the end of the month in which the DRP's directions are received by the Assessing Officer. In the faceless regime, the point of receipt depends on the manner in which the DRP proceedings were initiated and transmitted through the ITBA system. The materials on record showed that the directions were uploaded to the National Faceless Assessment Centre on 22.06.2022, but they were transmitted to the Jurisdictional Assessing Officer only on 04.07.2022. The Court also relied on Section 13 of the Information Technology Act, 2000 to explain despatch and receipt of electronic records, and found that the direct receipt date pleaded by the petitioner could not be accepted on the facts.

Conclusion: The limitation period was correctly computed from 04.07.2022, and the assessment order dated 19.08.2022 was within time.

Ratio Decidendi: For the purpose of Section 144C(13), the relevant date is the date on which the Assessing Officer receives the DRP directions in the manner applicable to the faceless assessment workflow, and not merely the date of upload or communication to another system node.

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