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    <title>2025 (9) TMI 1436 - ITAT DELHI</title>
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    <description>Limitation under section 144C(13) depended on when the DRP directions were received by the Assessing Officer. The majority held that mere uploading of the directions on the ITBA portal did not amount to receipt, because the DRP proceedings had been initiated manually and the directions became visible to the assessment unit only later; the final assessment had to be completed within one month from the end of the month of receipt, so the order dated 30.06.2022 was time-barred and jurisdiction. The dissenting member held that the directions were received on 20.05.2022, making the assessment order within time.</description>
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      <title>2025 (9) TMI 1436 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=778947</link>
      <description>Limitation under section 144C(13) depended on when the DRP directions were received by the Assessing Officer. The majority held that mere uploading of the directions on the ITBA portal did not amount to receipt, because the DRP proceedings had been initiated manually and the directions became visible to the assessment unit only later; the final assessment had to be completed within one month from the end of the month of receipt, so the order dated 30.06.2022 was time-barred and jurisdiction. The dissenting member held that the directions were received on 20.05.2022, making the assessment order within time.</description>
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