The assessee’s case was referred to the Dispute Resolution Panel (DRP). The DRP’s directions were uploaded in the Income-tax Business Application (ITBA) portal on 31-1-2022, which was accessible to both the assessee and the Faceless Assessing Officer. However, as per case history, the AO recorded receipt of the DRP order on 3-2-2022 and completed the final assessment on 22-3-2022. The Department contended that limitation should commence from 3-2-2022, whereas the assessee argued that limitation commenced from 31-1-2022, the date of uploading in ITBA. The High Court held that section 144C of the Act is a self-contained code prescribing strict timelines for completion of assessment. Limitation cannot vary depending on internal processes or user functionalities in the ITBA. Since the DRP’s order was uploaded on 31-1-2022 and was accessible in the “360-degree screen” to the Faceless AO immediately, limitation had to be reckoned from that date. The assessment order dated 22-3-2022 was thus beyond limitation. The Tribunal was justified in holding the assessment time-barred. Held, assessment order barred by limitation. (AY 2017-18)
CIT v. Ramco Cements Ltd. (2025) 474 ITR 9 / 171 taxmann.com 306 (Mad)(HC)
S. 144B : Faceless Assessment-Limitation-Commencement of limitation period-Directions of DRP uploaded on 31-1-2022 in Income-tax Business Application portal-Order visible and accessible to AO on same date-AO cannot rely on later internal intimation dated 3-2-2022-Assessment completed on 22-3-2022 held barred by limitation.[S.143(3), 144B(3), 144C(13), 260A]