NETCRACKER TECHNOLOGY SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 5(1), HYDERABAD

ITA 730/HYD/2024Status: DisposedITAT Hyderabad03 December 2025Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the final assessment order, dated 06.06.2024, was passed beyond the extended 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 as being barred by limitation.

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, 1961. The primary contention was that the assessment order was barred by limitation as it was passed beyond the time prescribed under Section 153 of the Act.

What were the issues?

The key issue was whether the final assessment order was passed within the time limits prescribed under Section 153 of the Income-tax Act, 1961, especially in light of references made to the Transfer Pricing Officer.

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

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 06.06.2024,

2 NetCracker Technology Solutions (India) Private Limited,

in pursuance to the Directions dated 29.05.

The order continues below.

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