TBO Tek Ltd. vs. Assistant Commissioner of Income Tax & Ors.
Case No: ITA No. 1147/Del/2022, ITA No. 6734/Del/2017, ITA No. 575/Del/2021
Court: Income Tax Appellate Tribunal, Delhi Bench ‘I’
Date: 1/29/2026
Parties Involved
appellantTBO Tek Ltd.
respondentAssistant Commissioner of Income Tax
appellantDenso India P. Ltd.
respondentAdditional Commissioner of Income Tax
appellantCeva Logistics India P. Ltd.
respondentIncome Tax Officer/National e-Assessment Centre
Facts Summary
These three appeals by three different assessees (TBO Tek Ltd., Denso India P. Ltd., and Ceva Logistics India P. Ltd.) were taken up together as they involved identical issues. The assessees challenged 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 argued that the assessment orders were barred by limitation. The counsels for the assessees relied on the decision in CIT vs.…
Decision in favour of
Partly Assessee / Partly Revenue
Legal Issues
- 1. Whether the limitation for passing the final assessment order under section 144C(13) of the Act is to be determined solely with reference to section 144C or in conjunction with section 153 of the Act.
Precedents Relied Upon
9 precedents cited in this judgement.