Date of DRP Direction Upload Deemed Date of Receipt by AO: Telangana HC Rejects Income Tax Appeals [Read Order]
SUMMARY: The upload of Dispute Resolution Panel (DRP) directions constitutes the receipt of such directions by the Assessing Officer (AO).
![Date of DRP Direction Upload Deemed Date of Receipt by AO: Telangana HC Rejects Income Tax Appeals [Read Order]](https://images.taxscan.in/h-upload/2026/04/28/2134836-date-of-drp-direction-upload-deemed-date-of-receipt-.webp "Date of DRP Direction Upload Deemed Date of Receipt by AO: Telangana HC Rejects Income Tax Appeals [Read Order]")
The Telangana High Court held that the upload of Dispute Resolution Panel (DRP) directions constitutes the receipt of such directions by the Assessing Officer (AO). Following a prior Division Bench decision on identical facts, the Court ruled against the Revenue’s contention that the date of receipt should be when the directions became visible to the AO, rather than the date of the...
The Telangana High Court held that the upload of Dispute Resolution Panel (DRP) directions constitutes the receipt of such directions by the Assessing Officer (AO). Following a prior Division Bench decision on identical facts, the Court ruled against the Revenue’s contention that the date of receipt should be when the directions became visible to the AO, rather than the date of the manual upload by the DRP.
The batch of appeals involved four challenges filed by the Commissioner of Income Tax (International Taxation & Transfer Pricing) against orders passed by the Income Tax Appellate Tribunal (ITAT). The Revenue contested the ITAT's decision to treat the upload of DRP directions as the effective date of receipt.
Telangana HC Grants Pre-Arrest Bail in Alleged ₹167 Lakh Misappropriation Linked to IBC Liquidation[Read Order]
The appellant argued that when DRP proceedings are initiated through manual entry, the order does not automatically reflect in the AO’s case history module immediately. Therefore, the Revenue contended that the date on which the directions actually became visible to the AO (05.07.2022) should govern the limitation period, rather than the date of manual upload (30.06.2022).
The bench of Justice P. Sam Koshy and Justice Narsing Rao Nandikonda observed that the specific legal question raised in these appeals had already been decided by a Division Bench of the High Court on 09.01.2025. The Revenue's counsel did not dispute this precedent but informed the Court that the matter was currently pending consideration before the Supreme Court via Special Leave to Appeal.
The Court observed:
“Given the fact that identical set of matter has already been decided by this High Court, we see no reason why the same order should not be made applicable in the present set of appeals as well.”
The Court clarified that while the present judgment would follow the High Court's earlier order, it would remain subject to the final outcome of the Supreme Court’s decision on the pending challenge.
In view of this, the High Court dismissed the appeals filed by the Revenue. The legal question was decided against the Revenue in line with the order dated 09.01.2025, with the rider that the decision is subject to the Supreme Court's verdict. No costs were awarded.
Support our journalism by subscribing to Taxscan premium. Follow us on Telegram for quick updates
