Pioneer India Electronics P. Ltd. & Ors. vs. Deputy Commissioner of Income Tax & Ors.

Parties Involved

Facts Summary

These five appeals by five different assessees were taken up together as they involved identical issues. The assessees assailed the validity of the assessment orders on the ground of limitation as per the provisions of section 144C(13) read with section 153 of the Income Tax Act, 1961. The assessees raised the legal issue challenging the validity of the final assessment order on the ground of limitation. The counsels for the assessees placed reliance on the decision in CIT vs. Roca Bathroom Products P Ltd. and furnished date charts to ascertain the period of limitation. The Department objected to the adjudication of these appeals, citing that the issue is sub judice before the Hon’ble Apex Court and that the Supreme Court has restrained the citation of certain judgments as precedents.…

Legal Issues

• 1. Whether the limitation for passing the final assessment order under section 144C(13) of the Act is to be determined with reference to section 144C read with section 153 of the Act.

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

Similar Judgements

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• ITA No. 2072/Del/2022(A.Y 2018-19), ITA No. 7706/Del/2017(A.Y 2013-14), ITA No. 548/Del/2021(A.Y 2016-17), ITA No. 9237/Del/2019(A.Y 2015-16), ITA No. 183/Del/2022(A.Y 2017-18), IT (TP)A No. 5917/Del/2024(A.Y 2021-22), SA No.15/Del/2026

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