TMEIC INDUSTRIAL SYSTEMS INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE 2(1), HYDERABAD

ITA 898/HYD/2024Status: DisposedITAT Hyderabad12 December 2025AY 2020-21Bench: 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 order passed by the AO was barred by limitation. Therefore, the assessment order was quashed.

What were the facts?

The assessee filed an appeal against the assessment order for AY 2020-21. The assessee raised an additional ground regarding the inclusion of transfer pricing adjustment in book profits, which they argued was not permissible.

What were the issues?

Whether the transfer pricing adjustment was correctly included in the book profits for computing tax demand, and whether the assessment order was passed within the statutory limitation period.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 144B,Section 153(1),Section 153(4)

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

Before: Shri Ravish SoodShri Madhusudan Sawdia

Hearing: 08/12/2025

Per Madhusudan Sawdia, A.M.:

This appeal is filed by M/s. TMEIC Industrial Systems India Private Limited (“the assessee”), feeling aggrieved by the assessment order passed by the Learned Assessing Officer (“Ld. A.O), under section 143(3) r.w.s. 144C(13) r.w.s. 144B of the ITA No 898 of 2024 TMEIC Industrial Systems India P Ltd

Income Tax Act, 1961 (“the Act”) dated 25.07.2024 for the A.Y. 2020-21. 2. The assessee has raised the f

The order continues below.

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