MIH INTERNET SEA PTE LTD,SINGAPORE vs. ACIT, CIRCLE 2(2)(1), INTERNATIONAL TAXATION, NEW DELHI

ITA 1683/DEL/2023Status: 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 order was barred by limitation as per Section 153 read with Section 144C of the Act. The impugned final assessment order was quashed.

What were the facts?

The assessee's appeal challenged the final assessment order, contending it was time-barred. The assessment order was passed beyond the time frame prescribed under Section 153 read with Section 153(4) of the Income Tax Act, 1961.

What were the issues?

Whether the final assessment order passed by the Assessing Officer was time-barred, considering the interplay between Section 144C and Section 153 of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 153,Section 143(3),Section 144C(13),Section 153(1),Section 153(4)

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Income Tax Appellate Tribunal, DELHI

For Appellant: Adv (Virtual, Ms, Adv & Ms. Shruti Khimta
Hearing: 29/01/2026Pronounced: 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 27/04/2023 pertaining

to the Assessment Year 2017-18. 2. The Assessee raised Ground No. 1.5 contending that the Final

Assessment order dated 27/04/2023 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 1

The order continues below.

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