The petitioner filed its objection to the draft assessment order before the Dispute Resolution Panel (DRP), which passed its order on June 30, 2022. The respondent issued the final assessment order on August 30, 2022 which the petitioner claims was outside the period of limitation of one month from the end of the month in which the direction is issued by the DRP as prescribed by Section 144C(5). The court while interpreting the term “on receipt of” as mentioned in section 144C (13), laid emphasis on the definition given in the section 13(1) Information Technology Act, 2000. By relying on various judgements, the court held that the Assessment Orders were passed beyond the period of one month of receipt of directions by DRP, being barred by limitation, and thus set aside. (AY. 2018-19, 2019-20)