CIT Vs Rapsican Systems Inc. US (Telangana High Court)
The case involves a batch of four appeals filed by the Revenue challenging orders passed by the Income Tax Appellate Tribunal (ITAT) in matters concerning assessment proceedings. The central issue was whether the upload of directions issued by the Dispute Resolution Panel (DRP) could be treated as equivalent to receipt of those directions by the Assessing Officer, even when the directions became visible in the system at a later date.
The Revenue argued that although the DRP directions were uploaded earlier, they were not visible to the Assessing Officer until 05.07.2022. It was also contended that DRP proceedings involved manual processes such as manual dispatch or upload, and therefore, the upload date should not automatically be treated as the date of receipt. The Revenue questioned whether an earlier date like 30.06.2022 could be considered the date of receipt in such circumstances.
During the hearing, it was pointed out that the issue had already been decided by the same High Court in earlier writ petitions decided on 09.01.2025. The Revenue did not dispute that the matter had been settled by the Division Bench. However, it submitted that the earlier decision had been challenged before the Supreme Court and was pending consideration in a Special Leave Petition.
