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Google India Digital Services Pvt. Ltd. vs. AU

Case No: ITA No. 3311/Del/2024
Court: INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI BENCH ‘H’ NEW DELHI)
Date: 1/29/2026

Parties Involved

appellantGoogle India Digital Services Pvt. Ltd.
respondentAssessment Unit, NFAC, ACIT (OSD), Range

Facts Summary

The case pertains to an appeal filed by Google India Digital Services Pvt. Ltd. against the Final Assessment Order passed under Section 143(3) read with Section 144C(13) and Section 144B of the Income Tax Act, 1961, dated 27/05/2024 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 time limit 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. [2022] 445 537 (Madras) and various orders passed by the Co-ordinate Bench of the Tribunal, Hyderabad Bench. The respondent argues that the issue of limitation is unsettled and pending before the Hon'ble Supreme Court, hence the Tribunal should defer adjudication.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the Final Assessment Order passed on 27/05/2024 is time-barred under Section 153(1) read with Section 153(4) 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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