Samsung Data Systems India Pvt. Ltd. Vs. ITO
Parties Involved
Facts Summary
The case involves an appeal by Samsung Data Systems India Pvt. Ltd. against the Final Assessment Order passed by the Income Tax Officer on 28/06/2024 for the Assessment Year 2020-21. The appellant contends that the Final Assessment Order is time-barred and bad in law as it was passed beyond the time frame prescribed under Section 153(1) read with Section 153(4) of the Income Tax Act, 1961. The appellant 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. and orders passed by the Co-ordinate Bench of the Tribunal, Hyderabad Bench. The respondent argues that the issue of limitation is unsettled and pending adjudication before the Hon'ble Supreme Court, thus seeking deferral of adjudication.…
Decision in favour of
Assessee
Legal Issues
- 1. Whether the Final Assessment Order passed by the Income Tax Officer is time-barred under Section 153(1) read with Section 153(4) of the Income Tax Act, 1961.
Judgment Outcome
Decided in favour of Assessee.
Precedents Relied Upon
8 precedents cited in this judgement.
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