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TMI Blog2023 (7) TMI 974X X X X Extracts X X X X X X X X Extracts X X X X ..... ssion of the learned AR and the final assessment order passed is nonest in the eyes of law. Decided in favour of assessee. - IT(TP)A No.214/Bang/2022 - - - Dated:- 5-12-2022 - Shri N. V. Vasudevan, V.P. and Shri Laxmi Prasad Sahu, AM Appellant by : Sri. Nageswar Rao, Advocate Respondent by : Sri. K. Sankar Ganesh, JCIT-DR ORDER Per LAXMI PRASAD SAHU, AM : This is an appeal filed by the assessee against the final assessment order passed by the Assessing Officer on 02.02.2022 u/s 143(3) r.w.s. 144C(13) r.w.s. 144B of the I.T. Act. for the relevant assessment year 2017-2018. 2. The assessee has raised as many as 34 grounds, but during the course of hearing, the learned AR confined his argument only to ground No ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 22 by assessing the net income of Rs. 102,52,39,241. 5. Aggrieved by the final assessment order passed by the AO, the assessee has filed the present appeal before the Tribunal. The learned AR at the very outset, submitted that the final assessment order passed by the A.O. u/s 143(3) r.w.s. 144C(13) r.w.s. 144B of the Act dated 02.02.2022 is barred by limitation, as the A.O. should have passed his order within one month from the date of receipt of the directions of the DRP u/s 144C(13) of the Act. The directions were given by the learned DRP on 20.12.2021, and which was received by the A.O. on 30.12.2021. In support of his contention, the learned AR placed on record a paper book, inter alia, enclosing therein the judgment of the Hon ble S ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... has designated a computer resource, receipt occurs when the record enters the computer resource so designated. Otherwise, where no computer resource is designated, the receipt of the record is when it is retrieved by the addressee. These provisions have been incorporated in the law to enable the dispatch and receipt of a record in the electronic form to be defined with precision with reference to both time and place. 6. The learned Departmental Representative, on the other hand, relied on the orders of the authorities below, apart from placing on record the copy of the order sheet. 7. We have heard both the parties and perused the entire material available on record and the orders of the authorities below. On perusal of the directio ..... X X X X Extracts X X X X X X X X Extracts X X X X
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