Electronic receipt of DRP directions triggers section 144C(13) limitation, and the belated assessment order was quashed.

Electronic upload and email communication of DRP directions constituted receipt by the Assessing Officer for section 144C(13) limitation purposes, so the one-month period ran from the end of the month in which those directions were electronically made available. The physical receipt date could not extend the limitation once the directions had already been uploaded on the ITBA portal and emailed to the Assessing Officer. On that basis, the final assessment order dated 27.08.2024 was held time-barred and quashed.

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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 because the DRP directions were received by the Assessing Officer on the date of their electronic upload and email communication, and whether the order was liable to be quashed.

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 under section 144C(5) are received. The directions were uploaded on the ITBA portal and also sent by email on 27.06.2024, and this electronic availability constituted receipt on that date. The physical receipt date could not govern limitation when the directions had already been electronically communicated and made available to the Assessing Officer.

Conclusion: The final assessment order dated 27.08.2024 was held to be time-barred and was quashed, resulting in success for the assessee.

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