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        Case ID :
        Income Tax

        The HC held that DRP directions uploaded to the ITBA portal with...

        DRP directions uploaded to ITBA with DIN on 26/05/2022 treated as service under s.144C(13); assessment order on 01/07/2022 time-barred

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                The HC held that DRP directions uploaded to the ITBA portal with a DIN on 26.05.2022 constitute receipt by the assessing officer for limitation purposes under section 144C(13). Uploading ipso facto effects service; physical speed-post receipt on 01.06.2022 was inconsequential. Consequently the one-month limitation period expired on 30.06.2022 and the assessment order passed on 01.07.2022 is time-barred and therefore invalid. The court rejected the Revenue's contention that international taxation matters fall outside electronic communication, noting DRP directions were uploaded by the Revenue and electronic service under the e-Assessment Scheme governs computation of limitation. No substantial question of law arises.
                                Note: It is a system-generated summary and is for quick reference only.
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