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The HC held that the assessment orders dated 30.08.2022 and 01.09.2022 were issued beyond the permissible limitation period. As per Section 144C(13), the AO must complete proceedings within one month from the end of the month in which the DRP directions u/s 144C(5) are received. The HC ruled that when the DRP uploaded its directions on the portal on 30.06.2022, it amounted to 'despatch' u/s 13(2) of the IT Act, and the AO's 'receipt' occurred on the same date when the electronic record entered the department's computer resource. Thus, the limitation period began from 30.06.2022, not 05.07.2022 when the email was received, rendering the impugned orders time-barred.
The HC held that the assessment orders dated 30.08.2022 and 01.09.2022 were issued beyond the permissible limitation period. As per Section 144C(13), the AO must complete proceedings within one month from the end of the month in which the DRP directions u/s 144C(5) are received. The HC ruled that when the DRP uploaded its directions on the portal on 30.06.2022, it amounted to 'despatch' u/s 13(2) of the IT Act, and the AO's 'receipt' occurred on the same date when the electronic record entered the department's computer resource. Thus, the limitation period began from 30.06.2022, not 05.07.2022 when the email was received, rendering the impugned orders time-barred.
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