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Genpact India Private Limited vs Assessment Unit, Income Tax Department

Case No: ITA No. 4115/DEL/2024 (A.Y. 2020-21) and ITA No. 5017/DEL/2024 (A.Y. 2021-22)
Court: Income Tax Appellate Tribunal, Delhi Bench ‘H’ New Delhi
Date: 1/23/2026

Parties Involved

appellantGenpact India Private Limited
respondentAssessment Unit, Income Tax Department
respondentAssistant Commissioner of Income Tax (OSD), Range-10

Facts Summary

The case involves two appeals filed by Genpact India Private Limited against the Final Assessment Orders passed by the Income Tax Department for Assessment Years 2020-21 and 2021-22. The Assessee contends that the Final Assessment Orders are time-barred and void as they were passed beyond the statutory limitation prescribed under Section 153 read with Section 144C of the Income Tax Act, 1961. The Assessee relies on the judgment of the Madras High Court in the case of Commissioner of Income-tax Vs. Roca Bathroom Products (P.) Ltd. and orders passed by the Coordinate Bench of the Tribunal, Hyderabad Bench. The Department argues that the issue of limitation is unsettled and pending before the Supreme Court, thus seeking deferral of adjudication.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the Final Assessment Orders passed beyond the statutory limitation are void and liable to be quashed.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

4 precedents cited in this judgement.

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