Electronic receipt of DRP directions triggers limitation under section 144C(13), making the delayed assessment order time barred.

In the electronic assessment regime, upload of DRP directions on the ITBA portal constituted effective receipt for the purpose of section 144C(13), so the limitation period ran from that date and was not extended by any internal departmental delay. Applying that statutory scheme, the assessment had to be completed within one month from the end of the month of upload; as the directions were uploaded on 26.05.2022, the last permissible date was 30.06.2022. The assessment order passed on 01.07.2022 was therefore 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 26.05.2022 and the assessment order was passed on 01.07.2022.

Analysis: 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 Court held that, in the electronic assessment regime, upload of the DRP directions on the ITBA portal constituted sufficient and effective receipt for the purpose of limitation. The Court relied on the statutory scheme of electronic communication, the E-Assessment Scheme, 2019, and the principle that internal departmental delay in viewing or physically receiving the communication cannot enlarge the statutory period. The DRP directions were uploaded on 26.05.2022, so the assessment had to be completed by 30.06.2022.

Conclusion: The final assessment order dated 01.07.2022 was time barred and void, and the assessee succeeded on this issue.

Ratio Decidendi: For the purpose of section 144C(13), receipt of DRP directions in the electronic assessment framework occurs upon upload on the departmental portal, and the statutory limitation runs from that date, not from later physical or internal acknowledgment.

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