Electronic service of DRP directions triggers assessment limitation, making a belated final assessment time-barred and beyond jurisdiction.

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....Electronic uploading of Dispute Resolution Panel directions on the ITBA portal constitutes valid and sufficient service for calculating the deadline for a final assessment under section 144C(13). Where directions were uploaded in October 2025, the final assessment had to be completed by the end of November 2025. Completion in December 2025 exceeded the prescribed limitation period, rendering the final assessment beyond jurisdiction and time-barred. Other grounds challenging the assessment remain open because limitation disposed of the matter.....