LOUIS DREYFUS COMPANY INDIA PRIVATE LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 13(1), DELHI, NEW DELHI

ITA 5893/DEL/2024Status: DisposedITAT Delhi02 February 2026AY 2021-2217 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that Section 144C of the Act is a self-contained code with its own timelines, and the general limitation period under Section 153 does not apply to the final assessment order passed under Section 144C(13). The legislative intent is to provide an alternate dispute resolution mechanism, not to shorten the assessment process.

What were the facts?

Three assessees challenged their assessment orders on the grounds of limitation under Section 144C(13) read with Section 153 of the Income Tax Act, 1961. They argued that the final assessment orders were passed beyond the prescribed time limits.

What were the issues?

Whether the time limits prescribed under Section 153 of the Income Tax Act are applicable to the final assessment order passed under Section 144C(13), or if Section 144C operates as a special statutory mechanism with its own distinct timelines.

Which sections of the Income-tax Act were involved?

Section 144C,Section 153

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Cases cited in this judgment(6)Show list

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Heard together (3 matters)

ITA No. 5910/Del/2024
ITA No. 5893/Del/2024
ITA No. 5983/Del/2024

Read from the judgment's own cause title. This page is filed under one of them.

आयकर अपीलीय अधिकरण दिल्ली पीठ "आई", दिल्ली श्री विकास अवस्थी, न्यायिक सदस्य एवं श्री संजय अवस्थी, लेखाकार सदस्य के समक्ष IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “I”, DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER & SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER Taboola India P. Ltd., आअसं.5910/दिल्ली/2024(नि.व. 2021-22) 100, Babar Road, Opposite Hotel Lalit, Delhi 110001 PAN: AAFCT-1716-Q ...... अपीलार्थी/Appellant बनाम Vs.

Deputy Commissioner of Income Tax, Circle 25(1), CR Building, Delhi 110002 प्रतिवादी/Respondent आअसं.5893/दिल्ली/2024(नि.व. 2021-22)

Louis Dreyfus Company India P. Ltd., 68/2, RNM Centre, Janpath, Central Delhi, Delhi 110001 PAN: AAACL-7361-E ...... अपीलार्थी/Appellant बनाम Vs.

Deputy Commissioner of Income Tax, Circle 13(1), CR Building, Delhi 110002 प्रतिवादी/Respondent आअसं.5983/दिल्ली/2024(नि.व. 2021-22)

Federal-Mogul Ignition Products India Ltd., 10th Floor, Tower-B, Paras Twin Towers, Golf Course Road, Sector-54, Gurgaon, Haryana 122002 PAN: AAACF-4128-M ...... अपीलार्थी/Appellant बनाम Vs.

Deputy Commissioner of Income Tax, Circle 7(1), Range-40, CR

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