Faceless assessment limitation: ITBA upload of DRP directions starts the statutory clock, not later physical receipt.

Under section 144C(13) of the Income-tax Act, 1961, in a faceless assessment regime, uploading Dispute Resolution Panel directions on the ITBA portal with a DIN constitutes communication and receipt for computing limitation. The statutory period runs from the end of the month in which the directions are uploaded, and later physical receipt by the Assessing Officer does not extend or postpone that period. On that basis, the final assessment order passed after the prescribed time was held to be barred by limitation and was quashed.

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Issues: Whether the final assessment order passed pursuant to the Dispute Resolution Panel directions was barred by limitation on account of the date on which the directions were uploaded and communicated through the ITBA portal.

Analysis: The limitation under section 144C(13) of the Income-tax Act, 1961 runs from the end of the month in which the Dispute Resolution Panel directions are received. The directions were uploaded on the ITBA portal with DIN on 27.04.2022, and such upload constituted communication and receipt for the purpose of limitation. Physical receipt by the Assessing Officer at a later date did not postpone the statutory period. The Tribunal followed the binding view that, in the faceless regime, uploading of the directions on the portal is sufficient service and the clock starts from that date.

Conclusion: The final assessment order dated 27.06.2022 was beyond the permissible time limit and was rightly quashed as barred by limitation.

Ratio Decidendi: Under section 144C(13) of the Income-tax Act, 1961, in a faceless assessment regime, the uploading of Dispute Resolution Panel directions on the ITBA portal with DIN amounts to communication and receipt for computing limitation, and delayed physical receipt does not extend the prescribed period.

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