MUFG Bank Limited vs ACIT
Case No: ITA Nos. 134/D/23, 3929/D/24, 844/D/21, 1476/D/22 & 1477/D/2022
Court: Income Tax Appellate Tribunal, Delhi Bench ‘I’
Date: 1/27/2026
Parties Involved
appellantMUFG Bank Limited
respondentACIT, Circle 2(2)(1), International Taxation
Facts Summary
The present adjudication involves a batch of five appeals pertaining to MUFG Bank Limited for the assessment years 2016-17, 2017-18, 2018-19, 2019-20, and 2020-21. The assessee has challenged the validity of the assessment orders on the ground of limitation, considering the provisions of section 144C(13) read with section 153 of the Income Tax Act, 1961. The assessee argued that the assessment orders were passed beyond the stipulated deadline as per section 153 of the Act. The Revenue, however, …
Decision in favour of
Assessee
Legal Issues
- 1. Whether the limitation for passing the final assessment order under section 144C(13) of the Act is to be determined solely with reference to the timeline specified under section 144C or whether it should also consider the provisions of section 153 of the Act.
Precedents Relied Upon
5 precedents cited in this judgement.