JOHNSON MATTHEY INDIA P.LTD,NEW DELHI vs. DCIT, CIRCLE-13(2), NEW DELHI

ITA 2564/DEL/2022Status: DisposedITAT Delhi29 January 2026AY 2018-191 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the provisions of Sections 144C and 153 are mutually inclusive and the time limits prescribed therein are binding. Consequently, the final assessment orders were found to be barred by limitation.

What were the facts?

The Assessee challenged the final assessment orders, contending they were time-barred as passed beyond the limitation period prescribed under Section 153(1) read with Section 153(4) of the Income Tax Act. The Revenue argued that the issue of limitation was pending before the Supreme Court.

What were the issues?

Whether the final assessment orders passed after the period prescribed under Section 153(1) read with Section 153(4) are time-barred.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 144B,Section 153(1),Section 153(4),Section 158AB

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI

Before: YOGESH KUMAR U.S. & SHRI MANISH AGARWAL

For Appellant: Ms. Radhika, Ms. Soumya Pandey, Adv
Hearing: 22/01/2026Pronounced: 29/01/2026

Heard together (2 matters)

ITA No. 2564/DEL/2022
ITA No. 3953/DEL/2024

Read from the judgment's own cause title. This page is filed under one of them.

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 24/08/2022 pertaining to A.Y 2018-19 and 30/07/202

The order continues below.

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