INDEED INDIA OPERATIONS PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE2(1), HYDERABAD
What did the Tribunal hold?
The Tribunal held that the assessment orders were indeed barred by limitation as they were passed after the expiry of the time limits stipulated in Section 153 of the Act, including extensions. Consequently, the assessment orders were quashed.
What were the facts?
The assessee filed appeals against final assessment orders for AY 2020-2021 and 2021-2022. The primary contention was that the assessment orders were passed beyond the limitation period prescribed under the Income Tax Act.
What were the issues?
Whether the assessment orders passed by the Assessing Officer were barred by limitation as per Section 153 of the Income Tax Act, 1961.
Which sections of the Income-tax Act were involved?
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Cases cited in this judgment(11)Show listHide list
Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.
- 21. In SB Gurbaksh Singh v. Union of India318 citing37 STC 425 · 2007
- Commissioner of Income Tax v. Roca Bathroom Products (P) ltd.269 citing445 ITR 537 · 2022 · HC
- Shelf Drilling 4. In ACIT (International Taxation) v. Shelf Drilling Ron Tappmeyer Ltd.216 citing177 Taxmann.com 262 · 2025 · SC
- (i) Sultana Begum v. Prem Chand Jain187 citing1 SCC 373 · 1997
- Sultana Begum v. Prem Chand Jain147 citing259 ITR 449 · 2003 · SC
- State of Punjab v. Bhatinda District Coop. Milk Producers Union Ltd.140 citing11 SCC 363 · 2007
- CIT v. S. Teja Singh129 citing35 ITR 408 · 1959 · SC · Read judgment
- R.S. Raghunath v. State of Karnataka128 citing1 SCC 335 · 1992
- (ii) Govt. of India v. Citedal Fine Pharmaceuticals116 citing3 SCC 483 · 1989
- 126 Taxman 321/259 ITR 449; & Franklin Templeton Trustee Services (P.) Ltd. v. Amruta Garg78 citing124 Taxmann.com 326 · 2021
- Shelf Drilling Ron Tappmeyer Ltd. v. ACIT (International Taxation)30 citing457 ITR 161 · 2023 · HC
Income Tax Appellate Tribunal, Hyderabad ‘A’ Bench, Hyderabad
Before: SHRI VIJAY PAL RAO & SHRI MANJUNATHA G.
PER VIJAY PAL RAO, VICE PRESIDENT :
These two appeals by the Assessee are directed against the Final Assessment Orders dated 22.07.2024 and 20.10.2024 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
2 ITA.Nos.943 and 1359/Hyd./2024 "the Act"], 1961, for the assessment years 2020-2021 and 2021-2022, respectively.
ITA.No.943/Hyd./2024 – A.Y. 2020-2021 :
The has raised the following grounds of appeal :
“On the facts and in the circumstances of the case and in law, the Learned Transfer Pricing Officer i.e, the Deput
The order continues below.
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