Dnata International Pvt. Ltd. Vs. DCIT

Parties Involved

Facts Summary

The Assessee, Dnata International Private Limited, filed an appeal against the Final Assessment Order passed by the Assessing Officer under Section 143(3) read with Section 144C(13) and Section 144B of the Income Tax Act, 1961, dated 29/07/2024, pertaining to the Assessment Year 2020-21. The Assessee contended that the Final Assessment Order was time-barred and 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 arising from the interplay between Section 144C and Section 153 of the Act is unsettled and pending adjudication before the Hon'ble Supreme Court, thus seeking deferral of adjudication of the appeal.…

Legal Issues

• 1. Whether the Final Assessment Order passed by the Assessing Officer is time-barred and bad in law as it was passed beyond the time frame prescribed 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

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