TABOOLA INDIA PRIVATE LIMITED,NEW DELHI vs. ACIT, ASSESSMENT UNIT, NATIONAL FACELESS ASSESSMENT CENTRE, NEW DELHI

ITA 5910/DEL/2024Status: DisposedITAT Delhi02 February 2026AY 2021-202217 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that Section 144C provides a special mechanism for completing assessments after a draft order, and its timelines operate notwithstanding the general limitations under Section 153. The special regime of Section 144C governs the time from the draft order to the final assessment.

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 taken for proceedings under Section 144C, including those before the DRP, are subsumed within the limitation period prescribed by Section 153, or if Section 144C has 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

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