Time of Dispatch for Faceless Assessments Set by Upload Date on ITBA Portal Under IT Act Section 13

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....The ITAT held that for faceless assessments under sections 143(3) read with 144C(13) and 144B of the Income Tax Act, the time of dispatch and receipt of electronic documents is determined by the date of uploading on the ITBA portal, as per section 13 of the Information Technology Act, 2000. The DRP order was uploaded on 31.05.2024, establishing the critical timeline. Since section 144C(13) mandates completion of assessment within two years from the date of DRP order, the assessment was required by 31.05.2022. However, the assessment was completed on 30.06.2022, beyond the prescribed period. Consequently, the assessment order dated 30.07.2022 was declared time-barred and void ab initio. The impugned order was set aside, and the relevant ground of appeal was allowed.....