DRP Receipt Timing

This ruling addresses a procedural but high-stakes issue in faceless assessments, when DRP directions are deemed “received” for limitation purposes. 

The Court affirmed that digital upload itself completes communication, rejecting arguments based on backend visibility delays. 

While the decision follows earlier binding precedent, it introduces a cautionary overlay by making the outcome subject to Supreme Court adjudication. The ruling reinforces certainty in timelines but keeps the door open for final resolution at the apex level.