EXPRESS FREIGHT RAILWAY CONSORTIUM,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 28(1), NEW DELHI

ITA 3120/DEL/2025Status: DisposedITAT Delhi28 January 2026AY 2021-22Bench: SHRI C.N. PRASAD (Judicial Member), SHRI M. BALAGANESH (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal, relying on decisions from the Hon'ble Delhi High Court and other High Courts, held that the assessment order dated 27.03.2025 was indeed passed beyond the time limit prescribed under Section 144C(13) of the Act. The uploading of DRP directions on the ITBA portal was considered the effective date for computing the limitation period.

What were the facts?

The assessee filed an appeal against the final assessment order dated 27.03.2025. The primary ground raised by the assessee was that the assessment order was barred by limitation under Section 144C(13) of the Act. The assessee presented a timeline of events, including DRP directions and the AO's passing of the final assessment order, to support its claim.

What were the issues?

Whether the final assessment order passed by the AO was barred by limitation as per Section 144C(13) of the Income Tax Act, 1961.

Which sections of the Income-tax Act were involved?

Section 144C,Section 144C(13),Section 260,Section 144B,Section 270A,Section 234A,Section 234B,Section 234D,Section 153,Section 153B

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Income Tax Appellate Tribunal, DELHI BENCH, ‘I’: NEW DELHI

Before: SHRI C.N. PRASAD & SHRI M. BALAGANESH

Hearing: 11.12.2025Pronounced: 28.01.2026

PER C.N. PRASAD, JM, This appeal is filed by the assessee against the final assessment order dated 27.03.2025 passed u/s.144 r.w.s 260 r.w.s 144B. The assessee in its appeal raised the following grounds :-

1.

Legal Grounds pertaining to annulment of final assessment order 1 & mistakes apparent from record

(Please refer Para A of Annexure A for detailed grounds of appeal) Rs. 151452708

2.

Transfer Pricing adjustment of Rs. 19,23,88,103/-w.r.t payment 2 of lead member fee (Please refer Para B of Annexure A for detailed grounds of appeal) Rs. 151452708

3.

Without prejudice to above grounds, consideration of incorrect 3 transaction amou

The order continues below.

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