SIME DARBY ENGINEERING SDN BHD,GURGAON vs. DCIT (INTERNATIONAL TAXATION), CIRCLE-2, DEHRADUN

ITA 7616/DEL/2018Status: DisposedITAT Dehradun27 January 2026AY 2015-16Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)33 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal admitted the additional ground of appeal, holding that the assessment orders were indeed barred by limitation. Consequently, the Tribunal quashed the impugned final assessment orders.

What were the facts?

The assessee challenged the assessment orders passed by the AO, contending they were barred by limitation under Section 153 of the Income Tax Act. The assessee raised this as an additional ground of appeal, arguing it was a purely legal issue.

What were the issues?

Whether the assessment orders passed under Section 143(3) read with Section 144C(13) were barred by limitation as per Section 153 of the Act.

Which sections of the Income-tax Act were involved?

Section 153,Section 144C

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Income Tax Appellate Tribunal, DEHRADUN “DB” BENCH: DEHRADUN

Before: SHRI SATBEER SINGH GODARA & SHRI MANISH AGARWAL

For Appellant: Ms. Supriya Mehta
For Respondent: Shri Mohan Lal Joshi, Sr. DR
Hearing: 16/01/2026Pronounced: 27/01/2026

PER MANISH AGARWAL, AM: All the three captioned appeals are filed by the assessee against the separate final assessment order of AO passed u/s Sime Darby Engineering N BHD vs.DCIT 143(3)/144C(13) of the Income Tax Act, 1961 (“the Act” in short) subsequent to the direction of Ld. Dispute Resolution Panel DRP) as tabulated below: Sr. ITA No.

Asstt. DRP Final Nos.

Year Direction Assessment Dt.

Order dt. 1 7616/DDN/2018 2015-16 10.08.2018 27.09.2018 2. 9/DDN/2021 2017-18 20.01.2021 15.02.2021 3. 4

The order continues below.

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