Federal Mogul Ignition Products Vs. DCIT

Parties Involved

Facts Summary

The captioned appeal is filed by the Assessee, Federal Mogul Ignition Products, 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 30/07/2024 pertaining to the Assessment Year 2020-21. The Assessee contends that the Final Assessment order is time-barred by limitation 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. The Assessee relies 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. [2022] 445 537 (Madras) and orders passed by the Co-ordinate Bench of the Tribunal, Hyderabad Bench. The Department, represented by Sh. S. K. Jadhav, CIT DR, argues that the issue of limitation is unsettled and pending adjudication before the Hon'ble Supreme Court in the case of ACIT Vs. Shelf Drilling Ron Tappmeyer Ltd. and thus, the Tribunal should defer adjudication.…

Legal Issues

• 1. Whether the Final Assessment Order is time-barred by limitation under section 153 of the Income Tax Act, 1961.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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