CLAAS AGRICULTURAL MACHINERY PRIVATE LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 4(2), NEW DELHI, NEW DELHI

In the result, appeal of the Assessee is allowed

1) of the Act, is 18 months from the end\nof the relevant assessment year, which would expire on 30.09.2020 for A.Y. 2018-\n19. Further, as per the provisions of Section 153(4) of the Act, where a reference\nunder Section 92CA of the Act was made to the Transfer Pricing

M/S RELIGARE CAPITAL MARKETS LIMITED,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

153(1)(a) which stood at two years from the end of the assessment year. Section 92CA with the caption 'Reference to the Transfer Pricing

RELIGARE CAPITAL MARKETS LTD.,NOIDA vs. ACIT, NEW DELHI

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

153(1)(a) which stood at two years from the end of the assessment year. Section 92CA with the caption 'Reference to the Transfer Pricing

PR. COMMISSIONER OF INCOME TAX -7 vs. SUMITOMO CORPORATION INDIA (P) LTD.

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE RAVINDER DUDEJA

1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92CA; and [(ii) any non-resident not being a company, or any foreign company.] Time limit for completion of assessment, reassessment and recomputation. 153

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MICROSOFT INDIA ( R & D) PVT. LTD.

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92CA; and [(ii) any non-resident not being a company, or any foreign company.] Time limit for completion of assessment, reassessment and recomputation. 153

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MARUTI SUZUKI INDIA LTD.

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92CA; and [(ii) any non-resident not being a company, or any foreign company.] Time limit for completion of assessment, reassessment and recomputation. 153

BAXTER INDIA PRIVATE LIMITED,GURGAON, HARYANA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, NEW DELHI

In the result, appeals of the Assessee are allowed

Transfer pricing order under section 92CA(3) of the Act passed.\nDraft assessment order under section 144C of the Act passed.\nLimitation for passing the final assessment order expired on\n30.09.2021 i.e. 30 months (18 months+ 12 months) from April 01, 2019\nin view of section 153(1

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

In the result, appeals of the Assessee are allowed

1) of the Act, is 18 months from the end of the relevant assessment year,\nwhich would expire on 30.09.2020 for A.Y. 2018-19. Further, as per the\nprovisions of Section 153(4) of the Act, where a reference under Section 92CA of\nthe Act was made to the Transfer Pricing

HUAWEI TELECOMMUNICATIONS (INDIA) COMPANY PRIVATE LIMITED,GURGAON vs. ACIT, CIRCLE-1(1), GURGAON

In the result, all three appeals of the assessee are allowed, and the\nstay application is dismissed as being infructuous

Transfer Pricing Reference, such time available\nwith the A.O. and T.P.O will be only few months, effectively scuttling\npossibility of any meaningful verification or scrutiny of details\nfrustrating very purpose of entire scrutiny assessment related\nprovisions under the I.T. Act. Such a situation will be hit by doctrine\nof impossibility or doctrine of frustration and courts should avoid any\ninterpretation

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

1) of the Act, is 18 months from the end of the relevant assessment year,\nwhich would expire on 30.09.2020 for A.Y. 2018-19. Further, as per the\nprovisions of Section 153(4) of the Act, where a reference under Section 92CA of\nthe Act was made to the Transfer Pricing

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

In the result, appeals of the Assessee are allowed

1) of the Act, is 18 months from the end of the relevant assessment year,\nwhich would expire on 30.09.2020 for A.Y. 2018-19. Further, as per the\nprovisions of Section 153(4) of the Act, where a reference under Section 92CA of\nthe Act was made to the Transfer Pricing

WIN MEDICARE PRIVATE LIMITED,DELHI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT (DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 25(1), DELHI), DELHI

In the result, appeal of the Assessee is allowed

1) of the Act, is 18 months from the end\nof the relevant assessment year, which would expire on 30.09.2020 for A.Y. 2018-\n19. Further, as per the provisions of Section 153(4) of the Act, where a reference\nunder Section 92CA of the Act was made to the Transfer Pricing

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

In the result, appeal of the Assessee is allowed

1) of the Act, is 18 months from the end of the relevant\n assessment year, which would expire on 30.09.2020 for A.Y. 2018-19.\nFurther, as per the provisions of Section 153(4) of the Act, where a\nreference under Section 92CA of the Act was made to the Transfer Pricing

JOHNSON MATTHEY INDIA PVT. LTD.,DELHI vs. DCIT, CIRCLE-13(1), DELHI

In the result, appeal of the Assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2021-22] Johnson Matthey India Pvt. Vs. Dcit, Ltd., 5Th Floor, C/O Regus Circle-13(1) Business Center, Gurgaon C.R. Building, Delhi Road, South West Delhi- 110037. Pan-Aaacj2919A Appellant Respondent Assessee By Shri Sumit Mangal, Adv. Ms. Radhika Sharma, Adv. Ms. Soumya Pandey, Adv. Revenue By Shri S.K. Jadhav, Cit Dr Date Of Hearing 22.01.2026 Date Of Pronouncement 27.01.2026 Order Per Manish Agarwal, Am : 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.S. 144B Of The Income Tax Act, 1961 [“The Act”] Dated 23.10.2024 Pertaining To The Assessment Year 2021-22. 2. During The Course Of Hearing The Bench Has Asked The Assessee To File Specific Ground Of Appeal No.2 As Against General Ground Of Appeal No. 2 Taken. In Compliance, Assessee Vide Application Dt. 12.03.2025 Filed Under Rule 11 Of The Income Tax Appellate Tribunal Rules, 1963 Raised Additional Ground Of Appeal Under. The Additional Ground Of Appeal Taken Reads As Under: Johnson Matthey India Pvt. Ltd. Vs. Dcit

1) of the Act, is 18 months from the end of the relevant assessment year, which would expire on 30.09.2020 for A.Y. 2018-19. Further, as per the provisions of Section 153(4) of the Act, where a reference under Section 92CA of the Act was made to the Transfer Pricing

LS CABLE INDIA P.LTD.,REWARI vs. ADDL.CIT, SPECIAL RANGE-5, NEW DELHI

In the result, appeals of the Assessee in ITA No

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

1) of the Act, is 18 months from the end of the relevant assessment year, which would expire on 30.09.2020 for A.Y. 2018-19. Further, as per the provisions of Section 153(4) of the Act, where a reference under Section 92CA of the Act was made to the Transfer Pricing

LS CABLE INDIA PVT. LTD.,HARYANA vs. ACIT, NEW DELHI

In the result, appeals of the Assessee in ITA No

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

1) of the Act, is 18 months from the end of the relevant assessment year, which would expire on 30.09.2020 for A.Y. 2018-19. Further, as per the provisions of Section 153(4) of the Act, where a reference under Section 92CA of the Act was made to the Transfer Pricing

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.

1) of the Act, is 18 months from the end of the relevant assessment year, which would expire on 30.09.2020 for A.Y. 2018-19. Further, as per the provisions of Section 153(4) of the Act, where a reference under Section 92CA of the Act was made to the Transfer Pricing

ITRON INDIA P.LTD,DELHI vs. DCIT, CIRCLE-10(1), NEW DELHI

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalitron India P. Ltd. Vs The Deputy Commissioner Of Flat No. 507, Income Tax, Circle 10(1), Bhikajicamabhawan, C. R. Building, New Delhi Bhikajicama Place, New Delhi Pan: Aabcs6575L 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 29/01/2026

1) of the Act, is 18 months from the end of the relevant assessment year, which would expire on 30.09.2020 for A.Y. 2018- 19. Further, as per the provisions of Section 153(4) of the Act, where a reference under Section 92CA of the Act was made to the Transfer Pricing