QUALCOMM INDIA PRIVATE LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, NEW DELHI

ITA 4412/DEL/2024Status: DisposedITAT Delhi30 January 2026AY 2020-21Bench: 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 indeed barred by limitation. Following the precedent set by the Madras High Court in Roca Bathroom Products Pvt. Ltd., the Tribunal quashed the impugned assessment orders.

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 deferral, citing a pending Supreme Court case on a similar issue.

What were the issues?

Whether the final assessment orders were passed within the statutory time limits 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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Income Tax Appellate Tribunal, DELHI

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

For Appellant: Ms. Jasmine Amalsadwala, Adv (Virtual), CA & Sh. Nishant
Hearing: 28/01/2026Pronounced: 30/01/2026

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

31/01/2022 pertaining to A.Y 2017-18, dated 30/07

The order continues below.

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