HONDA TRADING ASIA COMPANY LIMITED,THAILAND vs. DCIT, INT. TAXATION, NOIDA

ITA 4936/DEL/2024Status: DisposedITAT Delhi28 January 2026AY 2020-2126 pages
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What did the Tribunal hold?

The Tribunal held that the final assessment order was passed beyond the prescribed limitation period and was liable to be quashed. However, other issues raised by the assessee were kept open pending the Supreme Court's decision.

What were the facts?

The assessee contended that the final assessment order was time-barred as it was passed beyond the statutory limitation prescribed under Section 153(1) read with Section 153(4) of the Income Tax Act, 1961. The Revenue sought deferral of adjudication due to the pendency of a similar issue before the Supreme Court.

What were the issues?

Whether the final assessment order was passed within the statutory time limit prescribed under Section 153 of the Income Tax Act, 1961. The impact of a pending Supreme Court case on the adjudication of the limitation issue.

Which sections of the Income-tax Act were involved?

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

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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 30/08/2024 pertaining to the Assessment Year 2020-21. 2. The Assessee raised Ground No. 2.1 contending that the Final Assessment order dated 30/08/2024 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

The order continues below.

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