ADP PRIVATE LIMITED,HYDERABAD, TELANGANA vs. DCIT., CIRCLE 1(1), HYDERABAD, TELANGANA

ITA 332/HYD/2025Status: DisposedITAT Hyderabad10 December 2025AY 2021-22Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)33 pages
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What did the Tribunal hold?

The Tribunal held that the final assessment order dated 06.12.2024 was passed beyond the time limit prescribed under Section 153(4) of the Act, considering the reference made to the Transfer Pricing Officer. Therefore, the assessment order was quashed.

What were the facts?

The assessee's appeal was against a final assessment order passed under Sections 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income-tax Act. The key issue was whether the assessment order was passed within the time limits prescribed by Section 153 of the Act.

What were the issues?

The primary issue was whether the assessment order was barred by limitation as per Section 153 of the Income-tax Act, 1961.

Which sections of the Income-tax Act were involved?

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

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Cases cited in this judgment(11)Show list

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

For Appellant: Ms. U. Mini Chandran

PER MANJUNATHA G., A.M : This appeal filed by the assessee is against the final assessment order passed under Sections 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income-tax Act, 1961 (for short “the Act”), dated

2 ADP Private Limited

06.12.

2024, in pursuance to the Directions dated 27.09.2024 of the learned Dispute Resolution Panel–1 (“DRP”), Bengaluru, passed under

The order continues below.

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