JUBILANT GENERICS LIMITED,GAUTAM BUDDHA NAGAR vs. ASSESSMENT UNIT, DELHI

ITA 4316/DEL/2024Status: DisposedITAT Delhi28 January 2026AY 2020-21Bench: YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (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, contending it was time-barred. The revenue requested deferral due to a pending Supreme Court case on a similar issue.

What were the issues?

Whether the final assessment order was passed beyond the time limit prescribed under Section 153 of the Income Tax Act, considering the interplay with Section 144C.

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

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Income Tax Appellate Tribunal, DELHI

For Appellant: Ms. Nidhi, AR (Virutal)
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.w. Section 144B

of the Income Tax Act, 1961 (the Act in short) dated 26/07/2024

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

Assessment order dated 26/07/2024 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

relying on the ratio laid down by the Hon'ble

The order continues below.

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