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    <title>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</title>
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    <description>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&#039;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.</description>
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    <pubDate>Fri, 31 Oct 2025 08:23:13 +0530</pubDate>
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      <title>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</title>
      <link>https://www.taxtmi.com/highlights?id=93746</link>
      <description>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&#039;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.</description>
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      <pubDate>Fri, 31 Oct 2025 08:23:13 +0530</pubDate>
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