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Beumer India (P.) Ltd. Vs. DCIT

Case No: ITA No. 2322 & 1599/Del/2023
Court: INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI BENCH ‘H’ NEW DELHI)
Date: 1/28/2026

Parties Involved

appellantBeumer India P. Ltd.
respondentThe Deputy Commissioner of Income Tax, Circle 4(2)

Facts Summary

The case involves Beumer India P. Ltd. challenging the Final Assessment Order passed under Section 143(3) read with Section 144C(13) and Section 144B of the Income Tax Act, 1961, dated 29/07/2022, pertaining to the Assessment Year 2018-19. The Assessee raised Additional Ground No. 10 contending that the Final Assessment order is time-barred by limitation and is bad in law as it was passed beyond the time frame prescribed under Section 153(1) read with Section 153(4) of the Act. The Assessee relied on the ratio laid down by the Hon'ble High Court of Madras in the case of Commissioner of Income-tax Vs. Roca Bathroom Products (P.) Ltd. and orders passed by the Co-ordinate Bench of the Tribunal, Hyderabad Bench. The Department's Representative argued that the issue of limitation is unsettled and pending adjudication before the Hon'ble Supreme Court.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the Final Assessment Order passed by the A.O. is time-barred by limitation under Section 153(1) read with Section 153(4) of the Income Tax Act, 1961.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

8 precedents cited in this judgement.

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