Express Freight Railway Consortium vs. DCIT

Parties Involved

Facts Summary

This appeal is filed by the assessee, Express Freight Railway Consortium, against the final assessment order dated 27.03.2025 passed under sections 144, 260, and 144B of the Income Tax Act. The assessee raised several grounds of appeal, including the annulment of the final assessment order due to it being barred by limitation under section 144C(13) of the Act. The assessee argued that the order was passed beyond the one-month timeline specified after the receipt of DRP directions. The relevant dates include the DRP directions issued on 30.09.2024, the TPO order on 21.10.2024, and the final assessment order on 27.03.2025. The assessee relied on several precedents to support their claim that the assessment order was time-barred.…

Legal Issues

• 1. Whether the final assessment order dated 27.03.2025 is barred by limitation under section 144C(13) of the Income Tax Act.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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• ITA No. 2072/Del/2022(A.Y 2018-19), ITA No. 7706/Del/2017(A.Y 2013-14), ITA No. 548/Del/2021(A.Y 2016-17), ITA No. 9237/Del/2019(A.Y 2015-16), ITA No. 183/Del/2022(A.Y 2017-18), IT (TP)A No. 5917/Del/2024(A.Y 2021-22), SA No.15/Del/2026