For AY 2022-23, the limitation prescribed under section 153(1), as amended by the Finance Act, 2022, required the assessment to be completed within twelve months from the end of the assessment year, i.e., on or before 31-3-2024. Though the Revenue contended that the assessment order was made on 31-3-2024, the order was undated and was reflected on the assessee’s portal only on 4-4-2024. In the absence of any contemporaneous evidence of service or uploading on 31-3-2024, and as no email containing the assessment order was shown to have been sent on that date, the Court held that the order was passed beyond limitation and was therefore time-barred. The Court further held that the Assessing Officer had violated principles of natural justice by issuing notices to an old email ID of a former Chartered Accountant despite intimation of fresh email IDs and by not granting personal hearing despite specific request. It was also found that the Assessing Officer had been influenced by superior officers during the assessment proceedings, whereas their role was confined only to approval of the final order under the CBDT Circular, resulting in abdication of quasi-judicial discretion. Accordingly, the assessment order was held to be illegal, arbitrary and non est, and was quashed.(AY. 2022-23)