Qualcomm India Private Limited Vs. ACIT
Parties Involved
Facts Summary
The captioned appeals are filed by Qualcomm India Private Limited challenging the respective Final Assessment Orders passed under Section 143(3) read with Section 144C(13) and Section 144B of the Income Tax Act, 1961, dated 31/01/2022 for A.Y 2017-18, 30/07/2022 for A.Y 2018-19, and 30/07/2024 for A.Y 2020-21. The Assessee contends that these orders are time-barred by limitation and bad in law as they were passed beyond the time frame prescribed under Section 153(1) read with Section 153(4) of the Income Tax Act, 1961. The Assessee relies on the judgment of the Hon'ble High Court of Madras in the case of Commissioner of Income-tax Vs. Roca Bathroom Products (P.) Ltd. [2022] 445 537 (Madras) and various orders passed by the Co-ordinate Bench of the Tribunal, Hyderabad Bench.…
Decision in favour of
Assessee
Legal Issues
- 1. Whether the Final Assessment Orders are time-barred by limitation under Section 153 read with Section 144C of the Income Tax Act, 1961.
Judgment Outcome
Decided in favour of Assessee.
Precedents Relied Upon
3 precedents cited in this judgement.
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