Itron India Pvt. Ltd. Vs. DCIT
Parties Involved
Facts Summary
The case involves an appeal by Itron India Pvt. Ltd. against the Final Assessment Order passed by the Deputy Commissioner of Income Tax, Circle 10(1), New Delhi. The assessee raised an additional ground contending that the Final Assessment Order dated 29/03/2022 is time-barred by limitation and is bad in law as it was passed beyond the time frame prescribed under section 153(1) read with section 153(4) of the Income Tax Act, 1961. The assessee relied on the ratio laid down by the Hon'ble High Court of Madras in the case of Commissioner of Income-tax Vs. Roca Bathroom Products (P.) Ltd. and several orders passed by the Co-ordinate Bench of the Tribunal, Hyderabad Bench. The Department's Representative submitted that the issue of limitation arising from the interplay between Section 144C and Section 153 of the Act is presently unsettled and pending adjudication before the Hon'ble Supreme Court.…
Decision in favour of
Assessee
Legal Issues
- 1. Whether the Final Assessment Order passed by the A.O. is time-barred by limitation 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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