SAMSUNG DATA SYSTEMS INDIA PRIVATE LIMITED,GURUGRAM vs. INCOME TAX OFFICER, NEW DELHI

ITA 3884/DEL/2024Status: DisposedITAT Delhi28 January 2026AY 2020-211 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the impugned Final Assessment Order was barred by limitation as per Section 153 r.w. Section 144C of the Act. Accordingly, the Tribunal quashed the assessment order. Liberty was granted to the parties to revive the appeal if a Supreme Court decision necessitates modification.

What were the facts?

The assessee filed an appeal challenging the Final Assessment Order passed under section 143(3) r.w.s. 144C(13) r. Section 144B of the Income Tax Act, 1961. The assessee's primary contention was that the assessment order was time-barred, having been passed beyond the period prescribed under section 153(1) read with section 153(4) of the Act.

What were the issues?

Whether the Final Assessment Order is time-barred due to passing beyond the prescribed limitation period under Section 153 of the Income Tax Act.

Which sections of the Income-tax Act were involved?

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

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI

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

Hearing: 22/01/2026Pronounced: 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. Section 144B of the Income Tax Act, 1961 (the Act in short) dated 28/06/2024 pertaining to the Assessment Year 2020-21. 2. The Assessee raised Additional Grounds of Appeal contending that the Final Assessment order dated 28/06/2024 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 und

The order continues below.

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