FUJITSU CONSULTING INDIA PRIVATE LIMITED,NEW DELHI vs. ACIT, CIRCLE-7(1), DELHI

ITA 1508/DEL/2022Status: DisposedITAT Delhi30 January 2026AY 2017-18Bench: YOGESH KUMAR U.S. (Judicial Member), SHRI KRINWANT SAHAY (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the assessment orders were barred by limitation, following the ratio of the Madras High Court in Roca Bathroom Products Pvt. Ltd. and other co-ordinate bench decisions. The assessment orders were quashed on this limited legal issue.

What were the facts?

The assessee contended that the final assessment orders were time-barred as they were passed beyond the period prescribed under Section 153 read with Section 144C of the Income Tax Act. The revenue sought to defer the adjudication pending a Supreme Court decision.

What were the issues?

Whether the final assessment orders were passed beyond the statutory time limit prescribed under Section 153 read with Section 144C of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 153,Section 144C,Section 143(3)

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Cases cited in this judgment(10)Show list

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Income Tax Appellate Tribunal, DELHI

Before: YOGESH KUMAR U.S. & SHRI KRINWANT SAHAY

Hearing: 28/01/2026Pronounced: 30/01/2026

Heard together (2 matters)

ITA No.1508 /DEL/2022
ITA No.3878/DEL/2024

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

PER YOGESH KUMAR, U.S. JM: The captioned appeals are filed by the Assessees challenging the respective Final Assessment Orders passed u/s 143(3) r.w.s. 144C(13)

r.w. Section 144B of the Income Tax Act, 1961 (the Act in short) dated

30/04/2022 pertaining to A.Y 2017-18, dated 30/05/2022 for A.Y

2018-19 and 30/09/2023 pertaining to A.Y 2020-21 respectively.

2.

The Assessees have raised Additional Ground No. 14in A.Y 2017-

18, Additional Ground No 14 in A.Y 2018-19 and Ground No. 1.1 in A.Y 2020-21 contending that

The order continues below.

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