Koch Business Solutions India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-4(3)(1), Bangalore
In the result, the appeal filed by the assessee is allowed
ITA 1844/BANG/2024[2020-21]Status: DisposedITAT Bangalore01 Apr 2026AY 2020-21
Bench: Shri Waseem Ahmed & Shri Keshav Dubey
For Appellant: Shri Chavali Narayan, A.RFor Respondent: Dr. Divya K.J., D.R
Section 143(3)
…& uploaded on the ITBA Portal, the same is received by the AO on the same date of uploading itself. 8.4 We also heavily relied on the decision of the Hon’ble Madras High Court in the case of Commissioner of Income Tax v. Ramco Cements Ltd. reported in (2025) 474 ITR 9, which clearly held that limitation cannot depend on varying user functionalities, which is an internal process that cannot be entertained since the same would defeat the purpose of statutory limitation. Further, the limitation cannot be reckoned in a manner so as to give rise to more than one interpretation where either party can take benefit of a…
