MSD PHARMACEUTICALS PRIVATE LIMITED,NEW DELHI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 16(1), NEW DELHI

ITA 4571/DEL/2024Status: DisposedITAT Delhi28 January 2026AY 2020-211 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal, following the ratio of the Madras High Court in CIT vs. Roca Bathroom Products (P) Ltd. and numerous orders of co-ordinate benches, 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 filed appeals challenging the Final Assessment Orders, arguing they were time-barred due to the Assessing Officer passing them beyond the period prescribed under Section 153(1) read with Section 153(4) of the Income Tax Act, 1961. The Revenue sought deferral of adjudication, citing a pending Supreme Court case on a similar issue.

What were the issues?

Whether the assessment orders passed by the Assessing Officer were time-barred under Section 153 read with Section 144C of the Income Tax Act, 1961.

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: Adv (Virtual), Sh, ADV Sh. S. K. Jadhav, CIT DR
Pronounced: 22/01/2026

Heard together (3 matters)

ITA No. 530/DEL/2022
ITA No. 2330/DEL/2022
ITA No. 4571/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 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 28/01/2022 pertaining to A.Y 2017-18, dated 28/07/2022 for A.Y 2018-19 and dated 03/08/2024 for the Assessment Year 2020-21 respectively.

2.

The Assessee raised Additional Grounds of Appeal No. 6, 10 and 34 for the Appeals filed for A.Y 2017-18 to 2020-21 res

The order continues below.

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