Limitation for DRP directions turns on actual receipt; uploaded directions alone did not save the assessment order from being time-barred.

Limitation under section 144C(13) depended on when the DRP directions were received by the Assessing Officer. The majority held that mere uploading of the directions on the ITBA portal did not amount to receipt, because the DRP proceedings had been initiated manually and the directions became visible to the assessment unit only later; the final assessment had to be completed within one month from the end of the month of receipt, so the order dated 30.06.2022 was time-barred and jurisdiction. The dissenting member held that the directions were received on 20.05.2022, making the assessment order within time.

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Issues: Whether the final assessment order passed under section 143(3) read with section 144C(13) of the Income-tax Act, 1961 was barred by limitation and therefore without jurisdiction.

Analysis: The dispute turned on the date on which the directions of the Dispute Resolution Panel were received by the Assessing Officer for the purpose of section 144C(13). The majority held that mere uploading of the directions on the ITBA portal did not, on the facts of the case, amount to receipt by the assessment unit when the DRP proceedings had been initiated manually and the directions became visible to the assessment unit only on a later date. Applying the statutory mandate that the assessment must be completed within one month from the end of the month in which the directions are received, the majority concluded that the order dated 30.06.2022 was passed beyond time. The dissenting view held that the jurisdictional Assessing Officer received the directions on a later date and that the order was within limitation.

Conclusion: The assessment order was time-barred and without jurisdiction; the limitation objection was accepted.

Dissenting Opinion: The Accountant Member held that the directions were received by the jurisdictional Assessing Officer on 20.05.2022 and that the assessment order dated 30.06.2022 was within the limitation prescribed by section 144C(13).

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