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Renew Solar Energy (TN) P. Ltd. & Ors. vs. Deputy Commissioner of Income Tax & Ors.

Case No: ITA Nos. 5907 to 5909/Del/2024 & 5788 & 5835/Del/2024 (A.Y 2021-22)
Court: Income Tax Appellate Tribunal, Delhi Bench ‘I’
Date: 1/28/2026

Parties Involved

appellantRenew Solar Energy (TN) P. Ltd.
respondentDeputy Commissioner of Income Tax, Circle 19(1)
appellantRenew Wind Energy (MP Two) P. Ltd.
respondentDeputy Commissioner of Income Tax, Circle 19(1), Range-44
appellantRenew Wind Energy (Rajkot) P. Ltd.
respondentDeputy Commissioner of Income Tax, Circle 19(1), Range-44
appellantAthena Bhiwadi Solar Power P. Ltd.
respondentDeputy Commissioner of Income Tax, Civic Center
appellantAthena Karnal Solar Power P. Ltd.
respondentAssessment Unit, Income Tax Department, Deputy Commissioner of Income Tax, Civic Centre

Facts Summary

These five appeals by five different assessees are taken up together as they involve identical issues. The assessees have assailed the validity of the assessment order 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 this legal issue challenging the validity of the final assessment order on the ground of limitation by raising a specific ground. The counsels for the assessees placed reliance on the decision in the case of CIT vs. Roca Bathroom Products P Ltd. and furnished a date chart tabulating the relevant dates for ascertaining the period of limitation within which the final assessment order was required to be passed and the dates on which the final assessment orders were actually passed by the Assessing Officer (AO).

Decision in favour of

Partly Assessee / Partly Revenue

Legal Issues

  • 1. Whether the assessment orders in the impugned assessment years are barred by limitation.

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

8 precedents cited in this judgement.

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