Faceless assessment limitation turns on ITBA upload date; delayed final order was held invalid and void ab initio.

Under the faceless assessment regime, the final assessment order was treated as time-barred where the DRP directions were uploaded on the ITBA portal after which the limitation under section 144C(13) expired before the order was digitally signed. Applying the principle that the portal upload date governs computation of limitation, the order passed beyond the statutory deadline was held invalid, void ab initio, and the assessment was quashed.

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Issues: Whether the final assessment order passed under the faceless assessment regime was time-barred under section 144C(13) of the Income-tax Act, 1961 and consequently void ab initio.

Analysis: The assessment proceedings arose from a transfer pricing reference and culminated in draft assessment proceedings, objections before the Dispute Resolution Panel, and directions issued under section 144C(5). The decisive question was whether the final assessment order was passed within the statutory period prescribed under section 144C(13). The relevant DRP directions were uploaded on the ITBA portal on 08.10.2025, and the final order was digitally signed on 01.12.2025. The statutory deadline expired on 30.11.2025. Relying on the principle that the date of uploading in the ITBA portal is the relevant date for reckoning limitation, the delay beyond the prescribed period rendered the final order invalid.

Conclusion: The final assessment order was held to be barred by limitation and void ab initio, and the assessment was quashed. The appeal was allowed.

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