MICROSOFT CORPORATION (INDIA) PVT LTD,DELHI vs. DCIT (16) (1) DELHI, DELHI
Appeal of the assessee is allowed
ITA 1862/DEL/2022[2017-18]Status: DisposedITAT Delhi04 Sept 2025AY 2017-18
Bench: Shri Mahavir Singh, Vice Presdient (), Shri Vikas Awasthy & Shri Brajesh Kumar Singhआअसं.1862/िद"ी/2022 (िन.व. 2017-18) Microsoft Corporation (India) P. Ltd., 807, New Delhi House, Barakhamba Road, New Delhi 110001 ...... अपीलाथ"/Appellant Pan: Aaacm-5586-C बनाम Vs. Deputy Commissioner Of Income-Tax, Circle 16(1), Central Revenue Building, ..... "ितवादी/Respondent Ip Estate, Delhi अपीलाथ" "ारा/ Appellant By : S/Shri Nageswar Rao, (Through Vc) & Parth, Advocates "ितवादी"ारा/Respondent By : Shri Rajesh Kumar, Cit- Dr सुनवाई क" ितिथ/ Date Of Hearing : 04/09/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 04/09/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 30.06.2022, Passed U/S. 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961, (Hereinafter Referred To As ‘The Act’) For Assessment Year 2017-18. 2. Shri Nageswar Rao, Appearing On Behalf Of The Assessee Submitted At The Outset That, At This Stage He Is Confining His Submissions To Ground No. 1 Of Appeal
For Appellant: S/Shri Nageswar Rao, (Through VC) &For Respondent: Shri Rajesh Kumar, CIT- DR
Section 143(3)Section 144C(13)Section 144C(5)
…e Act for passing of assessment order by the jurisdictional AO i.e., DCIT, Circle-16(1), Delhi. Learned Counsel for the assessee for this relied on the decision of Hon'ble Delhi High Court in the case of Louis Dreyfus Company India (P.) Ltd. Vs. DCIT – [2024] 464 ITR 595 (Delhi) and stated that Hon'ble Delhi High Court has considered this issue and held that uploading of 29 directives of DRP on ITBA portal would thus constitute valid and sufficient service and period of limitation as prescribed in Section 144C(13) of the Act would be liable to be computed from that date. He stated that the facts as were before Ho…
