21. In SB Gurbaksh Singh v. Union of India

2 SCC 181Supreme Court of India2007#243 most cited
318

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2008 to 2026.

Also referred to as

Rajesh Kumar v. Deputy CIT · SB Gurbaksh Singh v. Union of India · 2 SCC 181 · Section 143(3) · Section 144C · Section 153 · interpretation of law · assessment procedure · divergence of opinion · legal uncertainty

Also reported as

37 STC 425

Sections most often in play

Section 143(3)Section 144C(13)Section 153(4)Section 153(1)Section 153Section 144BSection 144CSection 153(2A)

Issues it is cited on

section 144cofsection 158absection 136section 261section 11(3)section 115bbe(b)section 153(4)impermissible avoidance arrangementsection 144c(4)section 193section 196section 43(3)

Judgments citing 21. In SB Gurbaksh Singh v. Union of India

Dnata International Private Limited, Haryana vs. DCIT, Circle 1(1), Gurgaon Or Assessment Unit, Income Tax Department, Gurgaon

In the result, appeal of the Assessee is allowed

ITA 4532/DEL/2024[2020-21]Status: DisposedITAT Delhi23 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaldnata International Private Vs Deputy Commissioner Of Limited. Ground Floor, R1, R2, Income Tax, Circle 1(1), Park Centra, Sector-30, Nh-8, Gurgaon Or Assessment Unit, Gurgaon, Haryana Income Tax Department, Pan: Aadcd7460P Gurgaon, Haryana Appellant Respondent Assessee By Sh. Nikhil Tiwari, Adv (Virtual) Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 23/01/2026

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 22 Dnata International Pvt. Ltd. Vs. DCIT 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of…

Signify Innovations India Limited, Haryana vs. Deputy Commissioner of Income Tax, Circle 3(1), Haryana

In the result, appeal of the Assessee is allowed

ITA 4510/DEL/2024[2020-2021]Status: DisposedITAT Delhi23 Jan 2026AY 2020-2021

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalsignify Innovations India Limited Vs Deputy Commissioner Of 9B, 9Th Floor, Dlf Cyber City, Income Tax, Circle 3(1), Range Dlf Qe, S.O. Gurgaon, Haryana Code 107, Income Tax Officer, Pan: Aaicp0987G Shankar Chowk, Phase V, Udyogvihar, Sector 19, Gurugram, Haryana Appellant Respondent Assessee By Ms. Reema Grewal, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 23/01/2026

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Coim India Private Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle 4(2), Delhi

In the result, appeal of the Assessee is allowed

ITA 4466/DEL/2024[2020-21]Status: DisposedITAT Delhi23 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalcoim India Private Limited Vs Deputy Commissioner Of Shop No. 4, Ground Floor Income Tax, Income Tax Rajendrabhawan, Patel Nagar, Department, Circle 4(2), East Central Delhi, Delhi Delhi Pan: Aabcy0901A Appellant Respondent Assessee By Sh. Nikhil Aggarwal, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026

Section 143(3)Section 144CSection 153Section 153(1)Section 153(4)Section 158A

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Haskoningdhv Consulting Private Limited, New Delhi vs. ACIT, Circle 10(1), New Delhi

In the result, appeal of the Assessee is allowed

ITA 4430/DEL/2024[2020-21]Status: DisposedITAT Delhi23 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalhaskoningdhv Consulting Vs The Assistant Commissioner Private Limited, Office No. 204, Of Income Tax, Circle 10(1), 2Nd Floor, Rs Tower, Plot No. B C. R. Building, New Delhi 358A, New No. 1267, New Ashok Nagar, Vasundhara Enclave, East Delhi Pan: Aaacm8966G Appellant Respondent Assessee By Sh. Harpreet Singh Ajmani, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Airbnb India Private Limited, Delhi, India vs. The Deputy Commissioner of Income Tax, Circle 1(1), Central Revenue Building, Delhi, India

In the result, the appeal of the Assessee is allowed

ITA 4331/DEL/2024[2020-21]Status: DisposedITAT Delhi23 Jan 2026AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalairbnb India Private Limited, Dcit, Circle-1(1), 5Th Floor, Caddie Commercial Central Revenue Building, Tower, Aerocity, Vs. Delhi. New Delhi-110037. Pan-Aakca5525B (Appellant) (Respondent) Assessee By Ms. Reema Grewal, Ca Department By Shri S.K. Jadhav, Cit-Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 23/01/2026 O R D E R Per Manish Agarwal, Am: The Present Appeal Is Filed By The Assessee Against The Final Assessment Order Passed By Ao Dated 24.07.2024 U/S 143(3) R.W.S. 144C(13) R.W.S. & 144B Of The Income Tax Act, 1961 (“The Act” In Short) For Assessment Year 2020-21 Subsequent To The Direction Of The Ld. Dispute Resolution Panel (Drp) Vide Direction Dated 27.06.2024. 2. The Assessee Raised Ground No. 2 Contending That The Final Assessment Order Dated 24/07/2024 Passed By The A.O. Is Time Barred By Limitation & Is Bad In Law, As It Has Been Passed Beyond The Time Frame Prescribed Under Section 153(1) Read With Section 153(4) Of The Income Tax Act, 1961 ('Act' For Short). The Ld. Assessee’S Representative Relying On The Ratio Laid Down By The Hon'Ble High Court Of Madras In The Case Of Commissioner Of Income-Tax Vs. Roca Bathroom Products (P.) Ltd. [2022] 445 537 (Madras) & Also Airbnb India Pvt. Ltd. Vs. Ito Plethora Of Orders Passed By The Co-Ordinate Bench Of The Tribunal, Hyderabad Bench Sought For Allowing The Ground No. 2 Of The Assessee.

Section 143(3)Section 144CSection 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Motorola Solutions India Private Limited, Gurgaon vs. Deputy Commissioner of Income Tax, Circle 1(1), Gurgaon

In the result, appeal of the Assessee is allowed

ITA 4324/DEL/2024[2020-21]Status: DisposedITAT Delhi23 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Avaya India Private Limited, Mumbai vs. Assessing Officer, NFAC, Not Available

In the result, appeals of the Assessee are allowed

ITA 4290/DEL/2024[2020-21]Status: DisposedITAT Delhi23 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Airbnb Payments India Private Limited, Gurugram, Haryana vs. The Deputy Commissioner of Income Tax, Circle 1(1), Gurugram, Haryana

In the result, the appeal of the Assessee is allowed

ITA 4263/DEL/2024[2020-21]Status: DisposedITAT Delhi23 Jan 2026AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalairbnb Payments India Private Dcit, Circle-1(1), Limited, Gurugram, Haryana. Level 9, Spaze I Tech Park, Vs A1 Tower, Sector-49, . Sohna Road, Gurugram-122018 Haryana. Pan-Aanca6203B (Appellant) (Respondent) Assessee By Ms. Reema Grewal, Ca Department By Shri S.K. Jadhav, Cit-Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 23/01/2026 O R D E R Per Manish Agarwal, Am: The Present Appeal Is Filed By The Assessee Against The Final Assessment Order Passed By Ao Dated 18.07.2024 U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 (“The Act” In Short) For Assessment Year 2020-21 Subsequent To The Direction Of The Ld. Dispute Resolution Panel (Drp) Vide Direction Dated 24.06.2024. 2. The Assessee Raised Ground No. 2 Contending That The Final Assessment Order Dated 18/07/2024 Passed By The A.O. Is Time Barred By Limitation & Is Bad In Law, As It Has Been Passed Beyond The Time Frame Prescribed Under Section 153(1) Read With Section 153(4) Of The Income Tax Act, 1961 ('Act' For Short). The Ld. Assessee’S Representative Relying On Airbnb Payments India Private Limited Vs. Dcit The Ratio Laid Down By The Hon'Ble High Court Of Madras In The Case Of Commissioner Of Income-Tax Vs. Roca Bathroom Products (P.) Ltd. [2022] 445 Itr 537 (Madras) & Also Plethora Of Orders Passed By The Co-Ordinate Bench Of The Tribunal, Hyderabad Bench Sought For Allowing The Ground No. 2 Of The Assessee.

Section 143(3)Section 144CSection 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

At and T Communication Services India Private Limited, New Delhi vs. Assistant Commissioner of Income Tax Circle 1(1), Office of ACIT, Cr Building, Delhi

In the result, appeal of the Assessee is allowed

ITA 4257/DEL/2024[AY 2020-21]Status: DisposedITAT Delhi23 Jan 2026

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Genpact India Private Limited, New Delhi vs. Assessment Unit, Income Tax Department, New Delhi

In the result, appeals of the Assessee are allowed

ITA 4115/DEL/2024[2020-21]Status: DisposedITAT Delhi23 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalgenpact India Private Limited Vs Assessment Unit, Income 12A, Ground Floor,K Prakash Tax Department, 2Nd Floor, Deep Building 7 Tolstoy Marg, E-Ramp, Jawaharlal Nehru Baroda House, S.O. Baroda Stadium, New Delhi House, Delhi Pan: Aabce4461B Appellant Respondent Genpact India Private Limited Vs Assistant Commissioner Of 12A, Ground Floor, Prakash Income Tax (Osd), Range-10 Deep Building 7 Tolstoy Marg, Central Revenue Building, Baroda House, S.O. Baroda Ito, New Delhi-110002 House, Delhi Pan: Aabce4461B Appellant Respondent Assessee By Sh. Sachit Jolly, Sr. Adv (Virtual) &Ms.Vyushtirawat, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Fmi Automotive Components Private Limited, Gurgaon vs. ACIT Circle 7(1), New Delhi

In the result, appeals of the Assessee are allowed

ITA 3838/DEL/2024[2020-21]Status: DisposedITAT Delhi23 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 144CSection 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Triumph Motorcycles (India) Private Limited, New Delhi vs. DCIT, Circle 25(1), New Delhi

In the result, appeal of the Assessee is allowed

ITA 794/DEL/2022[2017-18]Status: DisposedITAT Delhi23 Jan 2026AY 2017-18

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaltriumph Motorcycles (India) Vs The Pvt. Ltd. 2Nd Floor, Wing-A Additional/Joint/Deputy/Assista Radisson Blu Plaza, Nh-8, Nt Commissioner Of Income Tax, Mahipalpur, New Delhi Nfac, New Delhi Pan: Aaect1592M Appellant Respondent Assessee By Dr. Shaswat Bajpai, Adv (Virtual), Sh. Mayank Chaturvedi, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Fmi Automotive Components Pvt Ltd, Gurgaon vs. ACIT, Circle 7(1), New Delhi

In the result, appeals of the Assessee are allowed

ITA 2356/DEL/2022[2018-19]Status: DisposedITAT Delhi23 Jan 2026AY 2018-19

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 144CSection 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Amplus Kn Solar Private Limited, Gurgaon vs. ITO, Ward- 2(1), Delhi

In the result, appeal of the Assessee is allowed

ITA 2315/DEL/2022[2018-19]Status: DisposedITAT Delhi23 Jan 2026AY 2018-19

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalampluskn Solar Private Limited Vs Ito 6Th Floor, The Palm Square, Golf Ward-2(1), C. R. Building, Course Extension Road, Sector - New Delhi 66, Grugaon, Haryana Pan: Aapca3377G Appellant Respondent Assessee By Sh. Km Gupta, Adv, Ms.Shruti Khimta, Ar & Sh. Jaskaran Singh, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 23/01/2026

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)Section 158A

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Claas Agricultural Machinery Private Limited, New Delhi vs. Deputy Commissioner of Income-Tax, Circle 4(2), New Delhi

In the result, appeal of the Assessee is allowed

ITA 4563/DEL/2024[AY 2020-21]Status: HeardITAT Delhi21 Jan 2026

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Itron India Private Limited, Noida vs. The Assistant Commissioner of Income Tax, Circle 10(1), New Delhi

In the result, appeal of the Assessee is allowed

ITA 4389/DEL/2024[2020-21]Status: HeardITAT Delhi21 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalitron India Private Limited Vs The Assistant Commissioner C-7, Sector-3, Noida Gautam Of Income Tax, Circle 10(1), Budh Nagar, Uttar Pradesh C. R. Building, I. P. Estate, Pan: Aabcs6575L New Delhi Appellant Respondent Assessee By Sh. Kashish Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026

Section 143(3)Section 144BSection 144CSection 153Section 153(1)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Xl India Business Services Private Limited, Delhi vs. The Assistant Commissioner of Income Tax, New Delhi

In the result, appeal of the Assessee is allowed

ITA 4332/DEL/2024[2020-2021]Status: DisposedITAT Delhi21 Jan 2026AY 2020-2021

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 144CSection 153

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Lintec India Private Limited, South Delhi, Delhi vs. Deputy Commissioner of Income Tax Circle 13(1), Office of DCIT, Cr Building, Delhi

In the result, appeal of the Assessee is allowed

ITA 4282/DEL/2024[AY 2020-21]Status: HeardITAT Delhi21 Jan 2026

Bench: Yogesh Kumar U.S. & Shri Manish Agarwallintec India Private Limited Vs The Deputy Commissioner Of 14Th Floor, Eros Corporate Tower, Income Tax, Circle 13(1), Nehru Place, South Delhi, Delhi Office Of The Dcit, C. R. 110019, Building, Delhi Pan: Aaccl23772F Appellant Respondent Assessee By Sh. Supriya Mehta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026

Section 143(3)Section 144BSection 144CSection 144C(13)Section 153

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Al Maha Foods International Private Limited, New Delhi vs. National Faceless Assessment Centre (Jao - DCIT Circle 1(1), Delhi), New Delhi

In the result, appeal of the Assessee is allowed

ITA 3974/DEL/2024[2020-21]Status: DisposedITAT Delhi21 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalal Maha Foods International Vs National Faceless Private Limited, 1122, Dlf Assessment Centre (Jao- Tower A, Jasola, New Friends Dcit Circle 1(1), C. R. Colony, S.O. Zakir Nagar, Building, I. P. Estate, Delhi Delhi-110025 New Delhi Pan: Aabca8743L Appellant Respondent Assessee By Sh. Salil Kapoor, Adv& Ms. Ananya Kapoor, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026

Section 143(3)Section 144BSection 144CSection 153Section 153(1)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Teva Pharmaceutical & Chemical Industries India Private Limited, Mumbai vs. DCIT, Circle-25(1), Delhi

In the result, appeal of the Assessee is allowed

ITA 4197/DEL/2024[2020-21]Status: DisposedITAT Delhi19 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalteva Pharmaceutical & Chemical Vs Assessment Unit, Income Industries India Private Limited, Tax Department/Deputy 8Th Floor, C-Wing Time Square, Commissioner Of Income Andherikurla Road, Marol Naka, Tax, Circle 25(1), Opp Mittal Industrial Estate C. R. Building, Delhi- Andheri (E), Mumbai 400059, 110001 Maharashtra, India Pan: Bnspk7225H Appellant Respondent Assessee By Sh. Sachit Jolly, Sr. Adv, Sh. Sohamdua, Adv& Sh. Abhiudaya Shankar Bajpai, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 19/01/2026 Date Of Pronouncement 19/01/2026 Order 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 143Section 143(3)Section 144BSection 144CSection 144C(13)Section 153Section 153r

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…