DSM SHARED SERVICES INDIA PRIVATE LIMITED,HYDERABAD, TELANGANA vs. DCIT., CIRCLE 8(1), HYDERABAD

ITA 1358/HYD/2024Status: DisposedITAT Hyderabad12 December 2025AY 2021-22Bench: SHRI VIJAY PAL RAO (Vice President), SHRI MANJUNATHA G. (Accountant Member)39 pages
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What did the Tribunal hold?

The Tribunal held that the assessment order, passed on October 23, 2024, was indeed barred by limitation as the statutory time limit expired on December 31, 2023. Consequently, the assessment order was quashed.

What were the facts?

The assessee's appeal was against a final assessment order passed by the Assessing Officer. The primary contention was that the assessment order was barred by limitation as per Section 153 of the Income Tax Act.

What were the issues?

The key legal issue was whether the assessment order was passed within the prescribed time limit under Section 153 of the Income Tax Act, considering the provisions for reference to the Transfer Pricing Officer.

Which sections of the Income-tax Act were involved?

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

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Income Tax Appellate Tribunal, Hyderabad ‘B’ Bench, Hyderabad

Before: SHRI VIJAY PAL RAO & SHRI MANJUNATHA G.

Hearing: 09.12.2025

PER VIJAY PAL RAO, VICE PRESIDENT :

This appeal by the Assessee is directed against the Final Assessment Order dated 23.10.2024 passed by the Assessing Officer u/sec.143(3) r.w.s.144C(13) r.w.s.144B of the Income Tax Act [in short "the Act"], 1961, for the assessment year 2021-2022. 2 ITA.No.1358/Hyd./2024

2.

The has raised the following grounds of appeal :

“Each of the grounds and/ or sub-grounds of the appeal mentioned here-in are independent and without prejudice to each other.

I. General Ground

1.

On the facts and circumstances of the

The order continues below.

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