EPAM SYSTEMS INDIA PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

ITA 498/HYD/2022Status: DisposedITAT Hyderabad26 November 2025AY 2018-19Bench: SHRI VIJAY PAL RAO (Vice President), SHRI MANJUNATHA G. (Accountant Member)43 pages
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What did the Tribunal hold?

The Tribunal held that the assessment orders were barred by limitation. Consequently, the assessment orders were quashed on this legal issue.

What were the facts?

The assessee appealed against final assessment orders for AY 2017-18 and 2018-19. The appeals primarily concerned transfer pricing adjustments related to software development, employee compensation, and interest on delayed receivables.

What were the issues?

The key legal issue was whether the assessment orders were passed within the prescribed time limits, rendering them invalid if barred by limitation.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 144B,Section 147,Section 148,Section 153

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

Before: SHRI VIJAY PAL RAO & SHRI MANJUNATHA G.

For Respondent: MS U Mini Chandran, CIT-DR
Hearing: 24.11.2025

PER VIJAY PAL RAO, VICE PRESIDENT :

These two appeals by the assessee are directed against the Final Assessment Orders dated 28.01.2022 and 30.07.2022 passed by the Assessing Officer u/sec.143(3) r.w.s.144C(13) of the Income Tax Act [in short "the Act"],

2 ITA.Nos.83 and 498/Hyd./2022

1961, for the assessment years 2017-2018 and 2018-2019,

respectively.

ITA.No.83/Hyd./2022 – A.Y. 2017-2018 :

2.

The has raised the following grounds of appeal :

“The Appellant objects to the order of the National Faceless Assessment Centre, Delhi dated 28 January 2022

The order continues below.

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