Fujitsu India Pvt. Ltd. vs. ACIT
Parties Involved
Facts Summary
The case pertains to an appeal filed by Fujitsu India Pvt. Ltd. against the Final Assessment Order passed by the Assessing Officer under Section 143(3) read with Section 144C(13) of the Income Tax Act, 1961, for the Assessment Year 2020-21. The appellant contends that the Final Assessment Order is time-barred and invalid as it was passed beyond the statutory limitation period prescribed under Section 153(1) read with Section 153(4) of the Act. The appellant relies on the judgment of the Hon'ble High Court of Madras in the case of Commissioner of Income-tax Vs. Roca Bathroom Products (P.) Ltd. and various orders passed by the Co-ordinate Bench of the Tribunal, Hyderabad Bench. The Department, on the other hand, argues that the issue of limitation is currently unsettled and pending before the Hon'ble Supreme Court, hence the Tribunal should defer adjudication. However, the Tribunal rejected this argument and proceeded to decide the matter based on existing precedents.…
Decision in favour of
Assessee
Legal Issues
- 1. Whether the Final Assessment Order passed by the Assessing Officer is time-barred and invalid under Section 153 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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