In the result, captioned appeals of the Assessee in ITA No
Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]
28. It is respectfully submitted that the Hon'ble ITAT, Delhi, has consistently adopted a prudent and institutionally sound approach in matters where the assessee raises the preliminary issue of limitation involving the interplay of sections 144C and 153, by adjourning such matters sine die/deferring adjudication, noting that the controversy is pending consideration before the Hon'ble Supreme Court