Toyota Boshoku Device India Pvt. Ltd. vs. A.U
Parties Involved
Facts Summary
The case involves an appeal filed by Toyota Boshoku Device India Pvt. Ltd. against the Final Assessment Order passed by the Assessment Unit, Income Tax Department, Gurgaon, under Section 143(3) read with Section 144C(13) and Section 144B of the Income Tax Act, 1961. The appellant contends that the Final Assessment Order dated 28/05/2024 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 Act. 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 before the Hon'ble Supreme Court, thus seeking deferral of adjudication.…
Decision in favour of
Assessee
Legal Issues
- 1. Whether the Final Assessment Order dated 28/05/2024 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
4 precedents cited in this judgement.
Similar Judgements
Samsung Data Systems India Pvt. Ltd. Vs. ITO
Delhi Bench ‘H’ New Delhi benchAY 2020-21AllowedWin Medicare Pvt. Ltd. Vs. Assessment Unit
Delhi Bench ‘H’ New Delhi benchAY 2020-21AllowedGoogle India Digital Services Pvt. Ltd. vs. AU
Delhi Bench ‘H’ New Delhi benchAY 2020-21AllowedSignify Innovations India Ltd. vs. DCIT
Delhi Bench ‘H’ New Delhi benchAY 2020-21AllowedIndustic (India) Pvt. Ltd. Vs. ACIT
DELHI BENCH ‘H’ NEW DELHI benchAY 2015-16AllowedTriumph Motorcycles (India) P. Ltd. Vs. DCIT
Delhi Bench ‘H’ New Delhi benchAY 2017-18Allowed