Limitation for final assessment order turns on effective dispatch, not mere signature, under e-assessment rules.

The final assessment order under section 143(3) read with section 144C(13) was treated as time-barred where it was signed on 31 July 2024 but first served on 21 August 2024. The Tribunal noted that, after DRP directions under section 144C(5), completion had to occur within the statutory period and an order affecting rights becomes operative only when duly dispatched or made public, not merely when signed. It also referred to the e-assessment framework and section 13 of the Information Technology Act, 2000 for the timing of electronic delivery. On the admitted facts, there was no timely dispatch within limitation, so the assessment order was invalid.

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Issues: Whether the final assessment order under section 143(3) read with section 144C(13) of the Income-tax Act, 1961 was time-barred because it was signed on 31 July 2024 but first served on the assessee only on 21 August 2024.

Analysis: The assessment sequence showed that the DRP issued directions under section 144C(5) of the Income-tax Act, 1961 and the final order was required to be completed within the statutory period. The assessee relied on the principle that an order affecting rights becomes operative only when it is duly made public or dispatched, not merely when signed. The Tribunal also noted the e-assessment framework, under which delivery of an electronic order is to be effected through the prescribed modes, with the time of dispatch and receipt governed by section 13 of the Information Technology Act, 2000. On the admitted facts, the order dated 31 July 2024 was served only on 21 August 2024, and there was no timely dispatch establishing completion within limitation.

Conclusion: The assessment order was barred by limitation and invalid.

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