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    <description>Section 144C(13) limitation in faceless assessment runs from the earliest point at which DRP directions are received and available in the system, not from a later internal administrative entry. The Tribunal examined ITBA functionality, affidavits in related proceedings, and the object of section 144C as a strict time-bound dispute resolution mechanism, and applied precedents that treat uploaded directions with generated DIN as accessible to the assessing authority. On that basis, the final assessment order passed beyond the statutory period was held time barred and unsustainable, and the additions made in it were deleted.</description>
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