Rapiscan Systems Pvt. Limited Vs ADIT (INT.TAX)-2 (Telangana High Court)
DRP Directions Binding Once Uploaded: Assessing Officer’s Timeline Under Section 144C(13) Clarified
In a significant judgment, the Telangana High Court in Rapiscan Systems Pvt. Ltd. Vs ADIT (INT.TAX)-2 has provided critical clarity on the mandatory timelines for the Assessing Officer (AO) under Section 144C(13) of the Income Tax Act. The case primarily addressed whether the DRP’s directions are binding upon being uploaded, marking a key development in the e-assessment process.
Background of the Case
Rapiscan Systems Pvt. Ltd., the petitioner in this case, challenged the failure of the Assessing Officer to complete the assessment within the timeline prescribed under Section 144C(13). The dispute arose after the directions of the Dispute Resolution Panel (DRP) were uploaded on the Income Tax Business Application (ITBA) portal but the order of assessment was not completed within the required timeframe.
The DRP’s directions were uploaded on June 24, 2022, on the portal, with subsequent dispatch through speed post on June 27, 2022. However, the assessment order was passed on July 25, 2022, well beyond the stipulated timeline.
Key Legal Issues and Findings
The central issue before the court was whether the DRP’s directions, once uploaded on the ITBA portal, were deemed to have been received by the Assessing Officer, and if the assessment should have been completed within one month of this date.
