Limitation under section 144C(13) begins on portal uploading of DRP directions, making late assessment orders legally invalid.

Limitation for completing an assessment following Dispute Resolution Panel directions is addressed under the statutory framework governing such proceedings. The notes explain that the one-month period begins when the directions are uploaded on the income tax portal, rather than on another date. Applying that trigger, the prescribed period had expired before the assessment order was passed. The operative consequence is that an assessment completed after expiry of the statutory period is treated as time-barred and invalid.

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Issues: Whether the final assessment order was barred by limitation under section 144C(13) of the Income-tax Act, 1961.

Analysis: The assessee challenged the assessment order as having been passed beyond the prescribed time after the Dispute Resolution Panel issued its directions. The decisive date was the uploading of the directions on the income tax portal, from which the one-month period for completion of assessment under section 144C(13) commenced. On the facts recorded, the order was passed after expiry of that statutory period.

Conclusion: The assessment order was held to be time-barred and invalid.

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