RENEW WIND ENERGY (RAJKOT) PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 19(1), DELHI

ITA 5909/DEL/2024Status: DisposedITAT Delhi02 February 2026AY 2021-202217 pages
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What did the Tribunal hold?

The Tribunal held that Section 144C and Section 153 of the Act are mutually inclusive and overlapping, and the limitation period for passing the final assessment order must be considered in conjunction with Section 153. As the assessment orders were passed beyond the period of limitation, they were quashed.

What were the facts?

Five appeals were filed challenging the validity of assessment orders on the grounds of limitation under Section 144C read with Section 153 of the Income Tax Act, 1961. The assessees contended that the final assessment orders were passed beyond the prescribed time limits.

What were the issues?

Whether the final assessment orders passed under Section 144C were barred by limitation as per Section 153 of the Income Tax Act, 1961.

Which sections of the Income-tax Act were involved?

Section 144C,Section 153

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Cases cited in this judgment(1)Show list

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Heard together (3 matters)

ITA No. 5907/Del/2024
ITA No. 5908/Del/2024
ITA No. 5909/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 आअसं.5907/दिल्ली/2024(नि.व. 2021-22)

Renew Solar Energy (TN) P. Ltd., 138, Ansal Chambers II, Bikaji Cama Place, New Delhi 110066, Delhi 110066 PAN: AAGCR-4805-B ...... अपीलार्थी/Appellant बनाम Vs.

Deputy Commissioner of Income Tax, Circle 19(1), CR Building, Delhi 110002 प्रतिवादी/Respondent आअसं.5908/दिल्ली/2024(नि.व. 2021-22)

Renew Wind Energy (MP Two) P. Ltd., 138, Ansal Chambers II, Bikaji Cama Place, New Delhi 110066, Delhi 110066 PAN: AAGCR-7484-Q ...... अपीलार्थी/Appellant बनाम Vs.

Deputy Commissioner of Income Tax, Circle 19(1), Range-44, CR Building, Delhi 110002 प्रतिवादी/Respondent आअसं.5909/दिल्ली/2024(नि.व. 2021-22)

Renew Wind Energy (Rajkot)P. Ltd., 138, Ansal Chambers II, Bikaji Cama Place, New Delhi 110066, Delhi 110066 PAN: AAFCR-4553-H ...... अपीलार्थी/Appellant बनाम Vs.

Deputy Commissioner of Income

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