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Athena Hisar Solar Power Pvt. Ltd. Vs DCIT

Case No: ITA No.5372/Del/2024
Court: Income Tax Appellate Tribunal, Delhi 'H' Bench
Date: 1/27/2026

Parties Involved

appellantAthena Hisar Solar Power Pvt. Ltd.
respondentDCIT

Facts Summary

The case involves an appeal by Athena Hisar Solar Power Pvt. Ltd. against the Final Assessment Order passed by the Assessing Officer on 26.09.2024 for the Assessment Year 2021-22. The appellant contends that the assessment order is time-barred and void as it was passed beyond the statutory limitation prescribed under Section 153 read with Section 144C of the Income Tax Act, 1961. The respondent argues that the issue of limitation is currently unsettled and pending before the Supreme Court, hence the Tribunal should defer adjudication. The appellant relies on the judgment of the Madras High Court in Roca Bathroom Products (P) Ltd. and orders from the Hyderabad Bench of the Tribunal, while the respondent cites the interim order of the Supreme Court in Shelf Drilling Ron Tappmeyer Ltd. and argues for deferral.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the Final Assessment Order passed on 26.09.2024 is time-barred under Section 153 read with Section 144C of the Income Tax Act, 1961.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

4 precedents cited in this judgement.

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