FEDERAL-MOGUL IGNITION PRODUCTS INDIA LIMITED,GURUGRAM vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 7(1), RANGE - 40, DELHI

ITA 4440/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 final assessment order was barred by limitation as per Section 153 read with Section 144C of the Act. The assessment order was quashed on this limited legal issue.

What were the facts?

The assessee challenged the final assessment order, arguing it was passed beyond the time limit prescribed under Section 153 read with Section 144C of the Income Tax Act. The revenue sought to defer the adjudication, citing a pending Supreme Court case on a similar issue.

What were the issues?

Whether the final assessment order was 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),Section 144B

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Income Tax Appellate Tribunal, DELHI

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

For Appellant: Ms. Nandita Singhal, Adv
Hearing: 28/01/2026

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)r.w. Section 144B of the Income Tax Act, 1961 (the Act in short) dated 30/07/2024 pertaining

to the Assessment Year 2020-21. 2. The Assessee raised Ground No. 1 & 2 contending that the Final

Assessment order dated 30/07/2024 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

2 Federal Mogul Ignition Produc

The order continues below.

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