SICPA India P. Ltd. vs. Deputy Commissioner of Income Tax
Parties Involved
Facts Summary
The assessee, SICPA India P. Ltd., filed appeals against the assessment orders for the assessment years 2014-15 and 2015-16, challenging the validity of the 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 assessee argued that the final assessment orders were passed beyond the permissible limitation period. The Department objected to the adjudication of the appeals, citing that the issue was sub judice before the Hon’ble Supreme Court and had been referred to a Larger Bench. The Department also relied on various precedents to argue that the limitation period should be determined solely under section 144C and not in conjunction with section 153.…
Decision in favour of
Assessee
Legal Issues
- 1. Whether the limitation period for passing the final assessment order under section 144C(13) of the Income Tax Act, 1961, should be determined with reference to section 144C read with section 153 of the Act.
Judgment Outcome
Decided in favour of Assessee.
Precedents Relied Upon
7 precedents cited in this judgement.
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