HEADSTRONG SERVICES INDIA PVT LTD,NEW DELHI vs. ACIT, CIRCLE 10(1) , NEW DELHI

ITA 2403/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 final assessment order was barred by limitation as it was passed beyond the prescribed time limits under Section 153 read with Section 144C of the Act. Consequently, the impugned order was quashed.

What were the facts?

The assessee challenged the final assessment order, arguing it was time-barred. The assessment order was passed beyond the statutory time limit prescribed under Section 153 read with Section 144C of the Income Tax Act.

What were the issues?

Whether the final assessment order passed by the Assessing Officer was barred by limitation as per the provisions of 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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Income Tax Appellate Tribunal, DELHI

For Appellant: MS. Snigdha Gautam, Adv
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 31/07/2022 pertaining to the Assessment Year 2018-19. 2. The Assessee raised Ground No. 1 contending that the Final

Assessment order dated 31/07/2022 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 Head

The order continues below.

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