Dismissing the appeal of the revenue, the Court held that in view of provisions of section 144C(13), date of uploading DRP order on ITBA Portal is to be considered as date of service to recipient and time for Assessing Officer to pass assessment order starts running from date of receipt of DRP order. Where DRP directions were uploaded on ITBA portal on 26-05-2022 with a DIN, as recorded from intimation letter, time for Assessing Officer to pass assessment order started running from 01-06-2022, and expired on 30-06-2022 and since same was passed on 01-07-2022, order was barred by limitation. (AY. 2018-19)
CIT (IT) v. Hyundai Rotem Co. (2025) 347 CTR 305/ 255 DTR 257 / 180 taxmann.com 18 / (2026) 484 ITR 448 (Delhi)(HC)
S. 144C : Reference to dispute resolution panel-Period of limitation-Date of uploading DRP order on ITBA Portal is to be considered as date of service to recipient and time for Assessing Officer to pass assessment order starts running from date of receipt of DRP order-Order was barred by limitation. [S.144C(13),153, 260A, 282]
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