VIVO MOBILE INDIA PRIVATE LIMITED,HARYANA, INDIA vs. ASSISTANCE COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DELHI

ITA 4408/DEL/2024Status: DisposedITAT Delhi28 January 2026AY 2020-21Bench: YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the impugned final assessment orders were barred by limitation as per Section 153 read with Section 144C of the Act. Consequently, the assessment orders were quashed.

What were the facts?

The assessee, Vivo Mobile India Pvt. Ltd., filed appeals challenging final assessment orders passed by the AO. The primary contention was that these orders were time-barred under Section 153 read with Section 144C of the Income Tax Act.

What were the issues?

Whether the final assessment orders passed by the Assessing Officer were time-barred due to the interplay between Section 144C and Section 153 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 MANISH AGARWAL

For Appellant: Ms. Kanika Jain, Adv
Hearing: 21/01/2026Pronounced: 28/01/2026

PER YOGESH KUMAR, U.S. JM: The captioned appeals are filed by the Assessee challenging the 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

29/04/2022 pertaining to A.Y 2017-18, 29/04/2022 for A.Y 2018-19

and 31/07/2024 pertaining to the Assessment Year 2020-21

respectively.

2.

The Assessee raised Additional Ground contending that the Final

Assessment 29/04/2022 pertaining to A.Y 2017-18, 29/04/2022 for A.Y 2018-19 and 31/07/2024 perta

The order continues below.

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