Denso India Private Limited & Anr. vs Assistant Commissioner of Income Tax
Parties Involved
Facts Summary
These appeals are filed by Denso India Private Limited and Denso Subros Thermal Engineering Centre India Private Limited challenging the Final Assessment Orders passed under Section 143(3) read with Section 144C(13) of the Income Tax Act, 1961 for the Assessment Years 2017-18 and 2018-19. The assessees raised the additional ground that the Final Assessment orders are time-barred by limitation and bad in law as they were passed beyond the time frame prescribed under Section 153(1) read with Section 153(4) of the Act. The assessees argued that the orders were passed after the statutory time limit expired, making them void ab initio. The Department argued that the issue of limitation is presently unsettled and pending before the Supreme Court, thus requesting deferral of adjudication.…
Decision in favour of
Assessee
Legal Issues
- 1. Whether the Final Assessment Orders passed are time-barred by limitation 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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