WESTERN UP TOLLWAY LIMITED,NEW DELHI vs. DCIT CIRCLE -8(1), HYDERABAD

ITA 67/HYD/2022Status: DisposedITAT Hyderabad12 December 2025AY 2017-18Bench: Shri Ravish Sood (Judicial Member), Shri Madhusudan Sawdia (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the assessment orders passed by the Assessing Officer were barred by limitation as they were issued beyond the statutory time limits prescribed under Section 153(1) read with Section 153(4) of the Income Tax Act. Consequently, the assessment orders were quashed.

What were the facts?

The appeals were filed by Western UP Tollway Ltd and Mahua Bharatpur Expressways Ltd against orders passed by the Assessing Officer. The core issue revolved around the validity of the assessment orders concerning transfer pricing adjustments and the timeliness of their issuance.

What were the issues?

The primary legal issue was whether the final assessment orders were passed within the statutory period of limitation prescribed under the Income Tax Act. A secondary issue concerned the validity of transfer pricing adjustments made by the TPO/AO.

Which sections of the Income-tax Act were involved?

Section 153,Section 143(3),Section 144C(13),Section 144B,Section 92C

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Income Tax Appellate Tribunal, Hyderabad ‘ A ‘ Bench, Hyderabad

Before: Shri Ravish SoodShri Madhusudan Sawdia

Hearing: 09/12/2025

Per Bench: These three appeals are filed by M/s. Western UP Tollway Ltd (2) and Mahua Bharatpur Expressways Ltd (1) (“the ITA TP Nos 67 an

The order continues below.

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