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Johnson Matthey India P. Ltd. Vs. DCIT

Case No: ITA Nos. 2564 & 3953/del/2024
Court: INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI BENCH ‘H’ NEW DELHI)
Date: 1/29/2026

Parties Involved

appellantJohnson Matthey India P. Ltd.
respondentDCIT

Facts Summary

The case involves two appeals filed by Johnson Matthey India P. Ltd. against the Final Assessment Orders passed by the Deputy Commissioner of Income Tax for Assessment Years 2018-19 and 2020-21. The Assessee contends that the Final Assessment Orders are time-barred and bad in law as they were passed beyond the statutory limitation period prescribed under Section 153(1) read with Section 153(4) of the Income Tax Act, 1961. The Assessee relies on the judgment of the Madras High Court in Roca Bathroom Products (P.) Ltd. and orders from 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 requesting deferral of adjudication.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the Final Assessment Orders passed beyond the statutory limitation period are valid.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

5 precedents cited in this judgement.

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