8. CIT vs. Ramco Cements Ltd.:
[2025] 474 ITR 9 (Mad):
A. Y. 2017-18: Date of order 19th December, 2024:
Ss.143(3), 144B and 144C(13) of ITA 1961
Assessment — Faceless assessment — Limitation — Date of commencement of limitation period — Reference to DRP — Directions of DRP uploaded on 31st January, 2022 in income-tax business application portal visible and accessible by AO — Intimation of order of DRP received by AO on 3rd February, 2022 and assessment completed on 22nd March, 2022 — Held, assessment order barred by limitation:
The order of the Dispute Resolution Panel (DRP) was uploaded on 31st January, 2022 in the Department’s portal of Income-tax Business Application for National e-Faceless Assessment Centre, Delhi. The order was received by the Assessing Officer on 3rd February, 2022 as per the case history data and the proceedings were completed by the Assessing Officer on 22nd March, 2022. On the questions of whether the date of receipt of direction of the DRP was 31st January 2022 or 3rd February, 2022 and whether the completion of proceedings by 22ndRead More