ROLLS-ROYCE INDIA PRIVATE LIMITED,NEW DELHI vs. ACIT, CIRCLE-19(1), DELHI

ITA 1672/DEL/2022Status: DisposedITAT Delhi30 January 2026AY 2018-19Bench: 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 provisions of Section 144C and Section 153 of the Act are mutually inclusive and interdependent. Following the ratio of the Madras High Court in Roca Bathroom Products Pvt. Ltd., the Tribunal quashed the final assessment order as being barred by limitation.

What were the facts?

The assessee contended that the final assessment order was time-barred as it was passed beyond the period prescribed under Section 153 read with Section 153(4) of the Income Tax Act. The assessment order was passed on 26/07/2024, while the statutory time limit for AY 2018-19 expired on 30/09/2021.

What were the issues?

Whether the final assessment order passed under Section 143(3) r.w.s. 144C(13) is barred by limitation as per 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),Section 153(1),Section 153(4)

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Income Tax Appellate Tribunal, DELHI

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

PER YOGESH KUMAR, U.S. JM: The captioned appeal is filed by the Assessee challenging the Final

Assessment Order passed u/s 143(3) r.w.s. 144C(13) of the Income Tax

Act, 1961 (the Act in short) dated 28/06/2022 pertaining to the Assessment Year 2018-19. 2. The Assessee raised Ground No. 15 contending that the Final

Assessment order dated 28/06/2022 passed by the A.O. is time barred

by limitation and is bad in law, as it has been passed beyond the time

frame prescribed under section 153(1) read with section 153(4) of the Income Tax Act, 1961 ('Act' for short). The Ld. Assessee's Representative

relying on the ratio laid down by the Hon'ble High Court of Madras in the 2 Rolls-Royce

The order continues below.

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