DRP Upload Date Triggers Limitation – Final Order Passed Late Is Void ab initio

Corteva Agriscience Seeds Pvt. Ltd. Vs ACIT (ITAT Delhi) Delhi ITAT quashed the final assessment of Corteva Agriscience Seeds Pvt. Ltd. for AY 2018-19 as barred by limitation under section 144C(13). The Tribunal held that the date of uploading of DRP directions on the ITBA portal is the decisive date for computing limitation in the faceless regime, not the date on which an intimation email is received by the AO or NEAC. In the present case, DRP directions were dated 27-06-2022 and uploaded on ITBA on 28-06-2022. Accordingly, the AO was statutorily required to pass the final order by 31-07-2022...