Faceless assessment limitation runs from portal upload of DRP directions, making the later assessment order time barred.

In faceless assessment proceedings, the limitation period for passing the final assessment order under section 144C(13) runs from the date the DRP directions are uploaded on the ITBA portal, as electronic dispatch and receipt are governed by section 13 of the Information Technology Act, 2000 read with section 144B of the Income-tax Act, 1961. The record showed uploading on 31.05.2024, and on that basis the statutory period expired before the order dated 30.07.2024 was passed. The Department's reliance on later internal receipt or visibility to the assessment unit did not affect the limitation computation, so the assessment order was held time barred and void.

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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 DRP directions were uploaded on the ITBA portal on 31.05.2024 and the assessment order was passed on 30.07.2024.

Analysis: In faceless assessment proceedings, the relevant date for commencement of the time limit is the date on which the DRP directions are uploaded on the portal, because electronic dispatch and receipt are governed by section 13 of the Information Technology Act, 2000 read with section 144B of the Income-tax Act, 1961. The record showed 31.05.2024 as the date of uploading of the DRP directions. Once that date is taken as the date of receipt, the statutory period under section 144C(13) expired before the final assessment order was passed. The Department's contrary stand based on later internal receipt or visibility to the assessment unit did not alter the limitation computation.

Conclusion: The assessment order was time barred and void, and the limitation ground succeeded in favour of the assessee.

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