VIVO MOBILE INDIA PRIVATE LIMITED,GURGAON vs. ACIT, CIRCLE-25(1), DELHI

In the result, appeals of the Assessee are allowed

reassessment cannot be read into Section\n144C more particularly when the provisions of Section 153 are\nexcluded by the non-obstante clause in section 144C(13) and hence\nthe proceedings are not barred by limitation. Per contra, it has been\ncontended by the learned senior counsels appearing for the\nrespondent(s)/assessees that the outer time limit under Section

MSD PHARMACEUTICALS PRIVATE LIMITED,NEW DELHI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 16(1), NEW DELHI

In the result, appeals of the Assessee are allowed

reassessment cannot be read into Section\n144C more particularly when the provisions of Section 153 are\nexcluded by the non-obstante clause in section 144C(13) and hence\nthe proceedings are not barred by limitation. Per contra, it has been\ncontended by the learned senior counsels appearing for the\nrespondent(s)/assessees that the outer time limit under Section

JOHNSON MATTHEY INDIA P.LTD,NEW DELHI vs. DCIT, CIRCLE-13(2), NEW DELHI

In the result, appeals of the Assessees are allowed

reassessment cannot be read into Section\n144C more particularly when the provisions of Section 153 are\nexcluded by the non-obstante clause in section 144C(13) and hence\nthe proceedings are not barred by limitation. Per contra, it has been\ncontended by the learned senior counsels appearing for the\nrespondent(s)/assessees that the outer time limit under Section

MSD PHARMACEUTICALS PRIVATE LIMITED,NEW DELHI vs. DCIT, CIRCLE-16(1), DELHI

In the result, appeals of the Assessee are allowed

reassessment cannot be read into Section\n144C more particularly when the provisions of Section 153 are\nexcluded by the non-obstante clause in section 144C(13) and hence\nthe proceedings are not barred by limitation. Per contra, it has been\ncontended by the learned senior counsels appearing for the\nrespondent(s)/assessees that the outer time limit under Section

COMMISSIONER OF WEALTH TAX vs. S.S. AHLUWALIA

Section 124 ensures and prevents two assessments by different assessing officers, having or enforcing concurrent 2014:DHC:1423-DB ITA 255/2002 + connected Page 52 of 61 jurisdiction. There cannot be and the Act does not envisage two assessments for the same year by different officers. (Reassessment order can be by a different officer). (14) In view of the decision

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

reassessment cannot be read into Section 144C more\nparticularly when the provisions of Section 153 are excluded by the\nnon-obstante clause in section 144C(13) and hence the proceedings\nare not barred by limitation. Per contra, it has been contended by the\nlearned senior counsels appearing for the respondent(s)/assessees\nthat the outer time limit under Section

GBT INDIA PRIVATE LIMITED,NEW DELHI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT (JAO - ACIT(OSD), NEW DELHI

In the result, appeal of the Assessee is allowed

reassessment cannot be read into Section 144C more\nparticularly when the provisions of Section 153 are excluded by the\nnon-obstante clause in section 144C(13) and hence the proceedings\nare not barred by limitation. Per contra, it has been contended by the\nlearned senior counsels appearing for the respondent(s)/assessees\nthat the outer time limit under Section

MOTOROLA SOLUTIONS INDIA PRIVATE LIMITED,GURGAON vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1), GURGAON, GURGAON

In the result, appeal of the Assessee is allowed

reassessment cannot be read into Section 144C more\nparticularly when the provisions of Section 153 are excluded by the\nnon-obstante clause in section 144C(13) and hence the proceedings\nare not barred by limitation. Per contra, it has been contended by the\nlearned\nsenior\ncounsels\nappearing\nfor\nthe\n24\nITA No. 4324/Del/2024\nMotorola Solutions India (P) Ltd. Vs. DCIT

SAMSUNG DATA SYSTEMS INDIA PRIVATE LIMITED,GURUGRAM vs. INCOME TAX OFFICER, NEW DELHI

In the result, appeal of the Assessee is allowed

reassessment cannot be read into Section 144C more\nparticularly when the provisions of Section 153 are excluded by the\nnon-obstante clause in section 144C(13) and hence the proceedings\nare not barred by limitation. Per contra, it has been contended by the\nlearned senior counsels appearing for the respondent(s)/assessees\nthat the outer time limit under Section

BEAM GLOBAL SPIRITS AND WINE (INDIA) PRIVATE LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 4(2) ,,, ASSESSMENT UNIT, NFAC, NEW DELHI

In the result, appeal of the Assessee is allowed

reassessment cannot be read into Section\n144C more particularly when the provisions of Section 153 are\nexcluded by the non-obstante clause in section 144C(13) and hence\nthe proceedings are not barred by limitation. Per contra, it has been\ncontended by the learned senior counsels appearing for the\nrespondent(s)/assessees that the outer time limit under Section

VALVOLINE CUMMINS PRIVATE LIMITED,DELHI vs. DCIT, CIRCLE-25(1), DELHI

In the result, appeal of the Assessee is allowed

reassessment cannot be read into Section 144C more\nparticularly when the provisions of Section 153 are excluded by the\nnon-obstante clause in section 144C(13) and hence the proceedings\n24\nITA No. 4178/Del/2024\nValvoline Cummins Pvt. Ltd. Vs. DCIT\nare not barred by limitation. Per contra, it has been contended by the\nlearned senior counsels appearing for the respondent

HONDA TRADING ASIA COMPANY LIMITED,THAILAND vs. DCIT, INT. TAXATION, NOIDA

In the result, appeal of the Assessee is allowed

reassessment cannot be read into Section 144C more\nparticularly when the provisions of Section 153 are excluded by the\nnon-obstante clause in section 144C(13) and hence the proceedings\nare not barred by limitation. Per contra, it has been contended by the\nlearned senior counsels appearing for the respondent(s)/assessees\nthat the outer time limit under Section

MANLIFT INDIA PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX 16(3), NEW DELHI

In the result, appeal of the Assessee is allowed

reassessment cannot be read into Section\n144C more particularly when the provisions of Section 153 are\nexcluded by the non-obstante clause in section 144C(13) and hence\nthe proceedings are not barred by limitation. Per contra, it has been\ncontended by the learned senior counsels appearing for the\nrespondent(s)/assessees that the outer time limit under Section

AIRBNB INDIA PRIVATE LIMITED,DELHI, INDIA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1), CENTRAL REVENUE BUILDING, DELHI, DELHI, INDIA

In the result, the appeal of the Assessee is allowed

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.

reassessment cannot be read into Section 144C more particularly when the provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the proceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels appearing for the respondent(s)/assessees that the outer time limit under Section

INDUCTIS (INDIA) PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE- 12(1), NEW DELHI

In the result, appeal of the Assessee is allowed

reassessment cannot be read into Section 144C more\nparticularly when the provisions of Section 153 are excluded by the\nnon-obstante clause in section 144C(13) and hence the proceedings\nare not barred by limitation. Per contra, it has been contended by the\nlearned senior counsels appearing for the respondent(s)/assessees\nthat the outer time limit under Section

WABTEC LOCOMOTIVE PRIVATE LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 25(1), NEW DELHI, C R BUILDING, NEW DELHI

In the result, appeal of the Assessee is allowed

reassessment cannot be read into Section 144C more\nparticularly when the provisions of Section 153 are excluded by the\nnon-obstante clause in section 144C(13) and hence the proceedings\nare not barred by limitation. Per contra, it has been contended by the\nlearned senior counsels appearing for the respondent(s)/assessees\nthat the outer time limit under Section

JOHNSON MATTHEY INDIA PVT. LTD.,NEW DELHI vs. ACIT CIRCLE 13(1), , NEW DELHI

In the result, appeals of the Assessees are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaljohnson Matthey India P. Ltd. Vs The Deputy Commissioner Of C/O. Luthra & Luthra Law Income Tax, Circle 13(2) Office India, 103, Ashoka Estate, Spm Civic Centre, New Delhi Barakhamba Road, New Delhi Pan: Aaacj2919A Appellant Respondent Johnson Matthey India P. Ltd. Vs National Faceless Appeal 5Th Floor, C/O Regus Business Centre, Income Tax Center, Gurgaon, Road, South Department West Delhi Pan: Aaacj2919A Appellant Respondent Assessee By Sh. Sumit Mangal, Adv, Ms. Radhika Sharma, Adv& Ms. Soumya Pandey, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 29/01/2026

reassessment cannot be read into Section 144C more particularly when the provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the proceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels appearing for the respondent(s)/assessees that the outer time limit under Section

BEUMER INDIA P.LTD,NEW DELHI vs. DCIT, CIRCLE-4(2), NEW DELHI

In the result, appeal of the Assessee is allowed

reassessment cannot be read into Section 144C more\nparticularly when the provisions of Section 153 are excluded by the\nnon-obstante clause in section 144C(13) and hence the proceedings\nare not barred by limitation. Per contra, it has been contended by the\nlearned senior counsels appearing for the respondent(s)/assessees\nthat the outer time limit under Section