ETISALAT SOFTWARE SOLUTIONS P. LTD.,BENGALURU vs. ACIT, CIRCLE-2(2)(1), BENGALURU

ITA 92/BANG/2026Status: DisposedITAT Bangalore24 August 2026AY 2017-1811 pages
AI SummaryAllowed

What were the facts?

The assessee's appeal for AY 2017-18 was restored to the AO/TPO by a previous ITAT order. The TPO passed an order on 30 September 2024, and the final assessment order was passed on 12 November 2025.

What did the Tribunal hold?

The Tribunal held that the assessment order was barred by limitation as it was passed beyond the prescribed time limit of 31st March 2024, following jurisdictional High Court decisions. Consequently, the assessment order was quashed.

What were the issues?

Whether the assessment order passed by the Assessing Officer and the Transfer Pricing Officer was barred by limitation. The applicability of time limits prescribed under Section 153 of the Income Tax Act for passing orders after a remand by the Tribunal.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C,Section 254,Section 92CA,Section 153(3),Section 153(4),Section 153(5)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI SOUNDARARAJAN K.

PER SHRI PRASHANT MAHARISHI, VICE PRESIDENT:

1.

This appeal has been filed by Etisalat Software Solutions Private Limited (“the assessee/appellant”) for Assessment Year 2017–18 against the assessment order dated 12 November 2025 passed by the Assistant Commissioner of Income-tax, Circle-2(2)(1), Bengaluru (“the Assessing Officer/AO”). The order was passed pu

The order continues below.

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