Question 1

What are the key legal issues in ITA Nos. 5452/D/24, 1103/D/17, 600/D/21 with SA 225/D/25, ITAs 4325/D/24, 5747/D/24, 5319/D/24, 5735/D/24 & 5820/D/24?

Accepted Answer

1. Whether the assessment orders are barred by limitation under section 144C(13) r.w.s. 153 of the Income Tax Act, 1961.

Question 2

What are the facts of ITA Nos. 5452/D/24, 1103/D/17, 600/D/21 with SA 225/D/25, ITAs 4325/D/24, 5747/D/24, 5319/D/24, 5735/D/24 & 5820/D/24?

Accepted Answer

The present adjudication involves eight assessees who have challenged the validity of the assessment order on the ground of limitation considering the provisions of section 144C(13) r.w.s. 153 of the Income Tax Act, 1961. All these appeals involve the common issue of limitation and are being disposed of through this single order. The assessees argued that the assessment orders for the impugned assessment years are barred by limitation and relied on the decision in the case of Roca Bathroom Products (P) Ltd. The Revenue objected to the adjudication of these appeals, arguing that the issue was sub-judice before the Hon’ble Supreme Court and that proceeding with an identical matter would not be in the interest of judicial propriety.

ITA Nos. 5452/D/24, 1103/D/17, 600/D/21 with SA 225/D/25, ITAs 4325/D/24, 5747/D/24, 5319/D/24, 5735/D/24 & 5820/D/24

Parties Involved

Facts Summary

Legal Issues

Judgment Outcome

Precedents Relied Upon

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