2026 (5) TMI 216

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....he Income Tax Act, 1961 (hereinafter referred to as 'the Act'), for AY 2020-21. 2. The solitary issue assailed by the assessee in appeal is validity of final assessment order dated 30.07.2023, on the ground of limitation. 3. Shri Vishal Kalra, appearing on behalf of the assessee submits that pursuant to directions of the Dispute Resolution Panel (DRP) dated 30.05.2023, the Assessing Officer (AO) was duty bound to passed final assessment order within one month from the end of the month in which DRP directions were communicated to the AO. In the present case, the DRP directions were communicated by the DRP to the AO on 30.05.2023, that is on the date of passing directions itself. To substantiate his submissions, the ld. Counsel referred....

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....the email id of DRP-2, a bare perusal of the same clearly shows that DRP directions were communicated to the assessee, as well as, the AO on 30.05.2023. The said email is reproduced herein below:- 7. A report from the Director of Income Tax (Systems) was sought with respect to delivery status of the e-mail by DRP-2 on 30.05.2023 to the AO. As per the report the said e-mail was delivered to the AO on 30.05.2023 at 2127 Hrs. The said report is extracted herein under:- 8. Thus, on appreciation of facts in the instant case with reference to provisions of section 144C(13) of the Act and the proof of communication of DRP directions to the AO available on record, we have no hesitation in holding that the DRP directions were received by the A....

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.... ITAT matter Request for report on receipt of mail Date: 07/08/24 08:21 PM From: "Ddt5 systems./tba" Abhishek Sir JDIT-3 , Baxia ji , PUNAM INSP , Vikrant Ji JDIT Sir, Kindly refer to the trailing email. The matter was referred to the ITBA technical team for checking the details regarding the delivery status/time of the said email dated 30.05.2023 of DRP. The technical team has conveyed that as checked from database, the said E-mai 1 of DRP was triggered on the following email IDs: a)"To email id" : [email protected]. b) "CC email id" : "[email protected]. The delivery status of the email to the said recipient email addresses, as per the ITBA database, is as follows: Delivrzod Aime Stanh P ....