ITA Nos. 6031/D/2024, 3897/D/2019, 3922/D/2024, 3809/D/2024 & 549/D/2023
Case No: ITA Nos. 6031/D/2024, 3897/D/2019, 3922/D/2024, 3809/D/2024 & 549/D/2023
Court: INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH “I” NEW DELHI
Date: 1/28/2026
Parties Involved
appellantMUNJAL HOSPITALITY PRIVATE LIMITED
respondentThe Assessing Officer, National Faceless Assessment Centre, Circle-17(1), C.R. Building, Delhi
appellantZTE TELECOM INDIA PVT. LIMITED
respondentACIT, Circle-4(1), HSIIDC Building, Udyog Vihar, Phase-05, Gurgaon, Haryana
appellantINCEDO TECHNOLOGY SOLUTIONS LIMITED
respondentDCIT, Circle 10(1), Delhi
appellantMARATHON ELECTRIC INDIA PRIVATE LTD.
respondentASSESSMENT UNIT, The Income Tax Department, Delhi
appellantMICROSOFT CORPORATION (INDIA) P. LTD.
respondentDCIT, Circle 16(1), C.R. Building, New Delhi
Facts Summary
The present adjudication involves five assessees who have challenged the validity of the assessment order on the ground of limitation considering the provisions of section 144C(13) read with section 153 of the Income Tax Act, 1961. The assessees raised the ground of limitation through various General Orders of Appeal (GOAs) and Additional GOAs. The assessees argued that the assessment orders for the impugned assessment years are barred by limitation, relying on the decision in the case of Commis…
Decision in favour of
Partly Assessee / Partly Revenue
Legal Issues
- 1. Whether the limitation for passing the final assessment order under section 144C(13) of the Act is to be seen only with reference to the timeline specified under section 144C of the Act only without referring to provisions of section 153 of the Act.
Precedents Relied Upon
8 precedents cited in this judgement.