Coim India Pvt. Ltd. Vs. DCIT

Parties Involved

Facts Summary

The case pertains to an appeal filed by Coim India Private Limited against the Final Assessment Order passed by the Assessing Officer under Section 143(3) read with Section 144C(13) of the Income Tax Act, 1961, dated 30/07/2024 for the Assessment Year 2020-21. The appellant contends that the Final Assessment Order is time-barred and invalid as it was passed beyond the statutory limitation prescribed under Section 153(1) read with Section 153(4) of the Act. The appellant raised Additional Ground No. 10 to challenge the order on this basis. The respondent argued that the issue of limitation is currently unsettled and pending before the Supreme Court, hence the Tribunal should defer adjudication. The appellant relied on the judgment of the Madras High Court in Roca Bathroom Products (P.) Ltd. and orders from the Hyderabad Bench of the Tribunal to support their contention.…

Legal Issues

• 1. Whether the Final Assessment Order passed by the Assessing Officer is time-barred and invalid 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

Similar Judgements

• AT and T Communication Services India Pvt. Ltd. Vs. ACIT

  Delhi Bench benchAY 2020-21Allowed

• Fujitsu India Pvt. Ltd. vs. ACIT

  Delhi Bench ‘H’ New Delhi benchAY 2020-21Allowed

• Dora Medical Trading (India) Pvt. Ltd. vs. AO, Assessment Unit, Delhi

  Delhi 'H' Bench benchAY 2021-22Allowed

• Class Agricultural Machinery Private Limited Vs. The Deputy Commissioner of Income Tax

• Google India Digital Services Pvt. Ltd. vs. AU

  Delhi Bench ‘H’ New Delhi benchAY 2020-21Allowed

• Emaar India Limited Vs. ACIT

  Delhi Bench ‘H’ New Delhi benchAY 2020-21Allowed