Air Liquide Global E&C Solutions India P. Ltd. vs. Assessment Unit, Income Tax Department and MUFG Bank Ltd. vs. Assistant Commissioner of Income Tax
Parties Involved
Facts Summary
These two appeals by two different assessees, Air Liquide Global E&C Solutions India P. Ltd. and MUFG Bank Ltd., challenge the validity of the assessment orders on the ground of limitation as per the provisions of section 144C(13) read with section 153 of the Income Tax Act, 1961. The assessees argue that the final assessment orders were passed beyond the period of limitation. The Revenue, represented by Shri Dharam Veer Singh, raised objections to the adjudication of these appeals, citing that the issue is sub judice before the Hon’ble Supreme Court and that the operative part of a relevant judgment has been stayed by the Supreme Court. The Tribunal, however, rejected these objections and proceeded to hear the appeals on their merits.…
Decision in favour of
Partly Assessee / Partly Revenue
Legal Issues
- 1. Whether the limitation for passing the final assessment order under section 144C(13) of the Act is to be determined solely with reference to section 144C or in conjunction with section 153 of the Act.
Judgment Outcome
Decided in favour of Partly Assessee / Partly Revenue.
Precedents Relied Upon
8 precedents cited in this judgement.
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