BENTLEY SYSTEMS INDIA PRIVATE LIMITED,DELHI vs. DCIT, CIRCLE 4(2), DELHI ASSESSMENT UNIT, INCOME TAX DEPARTMENT, DELHI

ITA 4465/DEL/2024Status: DisposedITAT Delhi28 January 2026Bench: 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.

What were the facts?

The assessee challenged the final assessment order, contending it was time-barred. The revenue argued that the issue of limitation was pending before the Supreme Court and sought deferral.

What were the issues?

Whether the final assessment order was passed within the 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 143(3),Section 144C,Section 153

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Income Tax Appellate Tribunal, DELHI

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 29/07/2024 pertaining

to the Assessment Year 2020-21. 2. The Assessee raised Additional Ground No. 15 contending that the Final Assessment order dated 29/07/2024passed by the A.O. is time

barred by limitation and is bad in law, as it has been passed beyond the time fr

The order continues below.

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