Fujitsu Consulting India Pvt. Ltd. Vs. the ACIT
Parties Involved
Facts Summary
The captioned appeals are filed by Fujitsu Consulting India Pvt. Ltd. challenging the Final Assessment Orders passed under Section 143(3) read with Section 144C(13) and Section 144B of the Income Tax Act, 1961, dated 30/04/2022 for A.Y 2017-18, 30/05/2022 for A.Y 2018-19, and 30/09/2023 for A.Y 2020-21. The Assessee contends that these orders are time-barred 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 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 argues that the issue of limitation is unsettled and pending before the Hon'ble Supreme Court in the case of ACIT Vs. Shelf Drilling Ron Tappmeyer Ltd. and seeks deferral of adjudication.…
Decision in favour of
Assessee
Legal Issues
- 1. Whether the Final Assessment Orders are time-barred under Section 153 of the Income Tax Act, 1961.
Judgment Outcome
Decided in favour of Assessee.
Precedents Relied Upon
10 precedents cited in this judgement.
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