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HC held that statutory limitation for passing a Final Assessment Order under Section 144C cannot be dependent on user functionalities or internal processes. The limitation period commences from the earliest instance when DRP directions are visible to the assessing officer through the 360-degree view portal. The fact that no separate email was sent to the Assessing Officer does not impact the timeline, as the system provides real-time access to uploaded documents. Referencing precedents from Vodafone Idea Limited and Louis Dreyfus Company India Private Limited, the court decisively ruled in favor of the assessee, emphasizing that limitation provisions must have a strict and unambiguous interpretation to prevent potential misuse or multiple interpretations.
HC held that statutory limitation for passing a Final Assessment Order under Section 144C cannot be dependent on user functionalities or internal processes. The limitation period commences from the earliest instance when DRP directions are visible to the assessing officer through the 360-degree view portal. The fact that no separate email was sent to the Assessing Officer does not impact the timeline, as the system provides real-time access to uploaded documents. Referencing precedents from Vodafone Idea Limited and Louis Dreyfus Company India Private Limited, the court decisively ruled in favor of the assessee, emphasizing that limitation provisions must have a strict and unambiguous interpretation to prevent potential misuse or multiple interpretations.
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