TEVA PHARMACEUTICAL & CHEMICAL INDUSTRIES INDIA PRIVATE LIMITED,MUMBAI vs. DCIT, CIRCLE-25(1), DELHI

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalteva Pharmaceutical & Chemical Vs Assessment Unit, Income Industries India Private Limited, Tax Department/Deputy 8Th Floor, C-Wing Time Square, Commissioner Of Income Andherikurla Road, Marol Naka, Tax, Circle 25(1), Opp Mittal Industrial Estate C. R. Building, Delhi- Andheri (E), Mumbai 400059, 110001 Maharashtra, India Pan: Bnspk7225H Appellant Respondent Assessee By Sh. Sachit Jolly, Sr. Adv, Sh. Sohamdua, Adv& Sh. Abhiudaya Shankar Bajpai, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 19/01/2026 Date Of Pronouncement 19/01/2026 Order Per Yogesh Kumar, U.S. Jm: 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.

Pricing Officer under Section 92CA of the Act: consequently, the limitation to pass the Final Assessment Order was extended by 12 months under Section 153(4) of the Act. 4 Objections filed by the Appellant before the 27.10.2023 Dispute Resolution Panel in Form 35A within 30 days of receipt of the draft order. in compliance with Section 144C(2

COIM INDIA PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 4(2) , DELHI

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalcoim India Private Limited Vs Deputy Commissioner Of Shop No. 4, Ground Floor Income Tax, Income Tax Rajendrabhawan, Patel Nagar, Department, Circle 4(2), East Central Delhi, Delhi Delhi Pan: Aabcy0901A Appellant Respondent Assessee By Sh. Nikhil Aggarwal, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026

Pricing Officer under Section 92CA of the Act: consequently, the limitation to pass the Final Assessment Order was extended by 12 months under Section 153(4) of the Act. 4 25.10.2023 4. Objections filed by the Appellant before the Dispute Resolution Panel in Form 35A within 30 days of receipt of the draft order. in compliance with Section 144C(2

SIGNIFY INNOVATIONS INDIA LIMITED,HARYANA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(1), HARYANA

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalsignify Innovations India Limited Vs Deputy Commissioner Of 9B, 9Th Floor, Dlf Cyber City, Income Tax, Circle 3(1), Range Dlf Qe, S.O. Gurgaon, Haryana Code 107, Income Tax Officer, Pan: Aaicp0987G Shankar Chowk, Phase V, Udyogvihar, Sector 19, Gurugram, Haryana Appellant Respondent Assessee By Ms. Reema Grewal, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 23/01/2026

pricing order under section 92CA(3) of the Act passed. 26.09.2023 : Draft assessment order under section 144C(1) of the Act passed 20.06.2024 : DRP directions under section 144C(5) of the Act issued. 31.07.2024 : Final Assessment order under section 143(3) r.w.s 144C(13) read with section 144B of the Act passed [Please note that this is rectified final assessment

DNATA INTERNATIONAL PRIVATE LIMITED,HARYANA vs. DCIT, CIRCLE 1(1), GURGAON OR ASSESSMENT UNIT, INCOME TAX DEPARTMENT, GURGAON

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaldnata International Private Vs Deputy Commissioner Of Limited. Ground Floor, R1, R2, Income Tax, Circle 1(1), Park Centra, Sector-30, Nh-8, Gurgaon Or Assessment Unit, Gurgaon, Haryana Income Tax Department, Pan: Aadcd7460P Gurgaon, Haryana Appellant Respondent Assessee By Sh. Nikhil Tiwari, Adv (Virtual) Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 23/01/2026

pricing order under section 92CA(3) of the Act 27 July, 2023 4 Draft Assessment Order 28 September 2022 5 DRP order 24 June 2024 6 24 Final Assessment Order 29 July 2024 8. The Hon'ble High Court of Madras in the case of Roca Bathroom Products Pvt. Ltd (supra) held that, time limit prescribed

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

55 LT 446 (PC)] AC at\np. 634, Curtis v. Stovin[(1889) 22 QBD 513 : 58 LJQB 174 : 60 LT\n772 (CA)] referred to in S. Teja Singh case [AIR 1959 SC 352 :\n(1959) 35 ITR 408]).\n18. The statute must be read as a whole and one provision of the\nAct should be construed with reference to other

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

In the result, appeal of the Assessee is allowed

55 LT 446 (PC)] AC at\np. 634, Curtis v. Stovin[(1889) 22 QBD 513 : 58 LJQB 174 : 60 LT\n772 (CA)] referred to in S. Teja Singh case [AIR 1959 SC 352 :\n(1959) 35 ITR 408]).\n18. The statute must be read as a whole and one provision of the\nAct should be construed with reference to other

FMI AUTOMOTIVE COMPONENTS PRIVATE LIMITED,MANESAR vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT (JAO- DCIT/ACIT, CIRCLE 7(1), NEW DELHI

In the result, appeals of the Assessee are allowed

Pricing Officer\n30.07.2021\n21.07.2023\n21.10.2023\n3.\nDate of draft assessment order issued by Ld.\nAssessing Officer\n29.09.2021\n29.09.2023\n13.12.2023\n4.\nDate of Directions issued by Ld. Dispute\nResolution Panel\n31.05.2022\n31.05.2024\n20.09.2024\n5.\nDate of final assessment order under Section\n143(3) read with Section 144C(13) of the Act\n26.07.2022\n26.06.2024\n30.10.2024\nB.\nCOMPUTATION OF TIME LIMITATION FOR PASSING

AL MAHA FOODS INTERNATIONAL PRIVATE LIMITED,NEW DELHI vs. NATIONAL FACELESS ASSESSMENT CENTRE (JAO - DCIT CIRCLE 1(1), DELHI), NEW DELHI

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalal Maha Foods International Vs National Faceless Private Limited, 1122, Dlf Assessment Centre (Jao- Tower A, Jasola, New Friends Dcit Circle 1(1), C. R. Colony, S.O. Zakir Nagar, Building, I. P. Estate, Delhi Delhi-110025 New Delhi Pan: Aabca8743L Appellant Respondent Assessee By Sh. Salil Kapoor, Adv& Ms. Ananya Kapoor, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026

Pricing the completion limit to complete Officer) (TPO order) of time-limit to assessment complete proceedings assessment 8. The Hon'ble High Court of Madras in the case of Roca Bathroom Products Pvt. Ltd (supra) held that, time limit prescribed u/s 153 of the Act has to be adhered to and that both Section 144C

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

In the result, appeals of the Assessee are allowed

Pricing Officer\n31.01.2021\n31.07.2021\n31.03.2023\n3.\nDate of draft assessment order issued by Ld.\nAssessing Officer\n21.06.2021\n28.09.2021\n29.09.2023\n4.\nDate of Directions issued by Ld. Dispute\nResolution Panel\n22.03.2022\n22.03.2022\n30.06.2024\n5.\nDate of final assessment order under Section\n143(3) read with Section 144C(13) of the Act\n29.04.2022\n29.04.2022\n31.07.2024\nB.\nCOMPUTATION OF TIME LIMITATION FOR PASSING

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

In the result, appeals of the Assessee are allowed

Pricing Officer\n31.01.2021\n31.07.2021\n31.03.2023\n3.\nDate of draft assessment order issued by Ld.\nAssessing Officer\n21.06.2021\n28.09.2021\n29.09.2023\n4.\nDate of Directions issued by Ld. Dispute\nResolution Panel\n22.03.2022\n22.03.2022\n30.06.2024\n5.\nDate of final assessment order under Section\n143(3) read with Section 144C(13) of the Act\n29.04.2022\n29.04.2022\n31.07.2024\nB.\nCOMPUTATION OF TIME LIMITATION FOR PASSING

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

Pricing Officer)\ncomplete\nassessment\nproceedings\nAtleast twelve\nmonth before the\nend of time limit\nto\ncomplete\nassessment\nproceedings\n30.09.2022\n31.05.2023\n(TPO Order)\n8. The Hon'ble High Court of Madras in the case of Roca Bathroom\nProducts Pvt. Ltd (supra) held that, time limit prescribed u/s 153 of the\nAct has to be adhered to and that both Section

LINTEC INDIA PRIVATE LIMITED,SOUTH DELHI, DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 13(1), OFFICE OF DCIT, CR BUILDING, DELHI,

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwallintec India Private Limited Vs The Deputy Commissioner Of 14Th Floor, Eros Corporate Tower, Income Tax, Circle 13(1), Nehru Place, South Delhi, Delhi Office Of The Dcit, C. R. 110019, Building, Delhi Pan: Aaccl23772F Appellant Respondent Assessee By Sh. Supriya Mehta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026

pricing order u/s 92CA(3) of 2023 2023 the Act 2 Date of passing of the draft September - Yes assessment order u/s 143(3) 27, 2023, r.w. Section 144C(1) of the Act 3 Date of passing of the June 19, - No Directions of the Dispute 2024 Resolution Panel (DRP) u/s 144C(5) of the Act 4 Date of passing

HASKONINGDHV CONSULTING PRIVATE LIMITED,NEW DELHI vs. ACIT, CIRCLE 10(1), NEW DELHI

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalhaskoningdhv Consulting Vs The Assistant Commissioner Private Limited, Office No. 204, Of Income Tax, Circle 10(1), 2Nd Floor, Rs Tower, Plot No. B C. R. Building, New Delhi 358A, New No. 1267, New Ashok Nagar, Vasundhara Enclave, East Delhi Pan: Aaacm8966G Appellant Respondent Assessee By Sh. Harpreet Singh Ajmani, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026

pricing reference. 4 30.9.2023 Limitation for concluding assessment in terms of Section 153(1) r.w.s Section 153(4) of the Act. Therefore, a valid final assessment order could have been passed latest by 30/09/2023 5 23/10/2023 Objections filed by the Page 57 of the Appellant before the DRP appeal set 6 21/6/2024 Directions passed u/s Page 27 of the 144C

EVERSUB INDIA PRIVATE LIMITED ,HARYANA vs. DCIT CIRCLE-22(2), DELHI

In the result, appeals of the Assessee are allowed

pricing order under section 92CA(3) of the Act passed.\n23.09.2021\nDraft assessment order under section 144C(1) of the Act passed.\n18.02.2022\nDRP directions under section 144C(5) of the Act issued.\n31.03.2022\nFinal Assessment order under section 143(3) r.w.s 144C(13) read with\nsection 144B of the Act passed.\n30.09.2021\nLimitation for passing the final assessment order

AIRBNB PAYMENTS INDIA PRIVATE LIMITED,GURUGRAM, HARYANA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1), GURUGRAM, HARYANA, GURUGRAM, HARYANA

In the result, the appeal of the Assessee is allowed

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalairbnb Payments India Private Dcit, Circle-1(1), Limited, Gurugram, Haryana. Level 9, Spaze I Tech Park, Vs A1 Tower, Sector-49, . Sohna Road, Gurugram-122018 Haryana. Pan-Aanca6203B (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 18.07.2024 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 24.06.2024. 2. The Assessee Raised Ground No. 2 Contending That The Final Assessment Order Dated 18/07/2024 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 Airbnb Payments India Private Limited Vs. Dcit 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 Itr 537 (Madras) & Also Plethora Of Orders Passed By The Co-Ordinate Bench Of The Tribunal, Hyderabad Bench Sought For Allowing The Ground No. 2 Of The Assessee.

Pricing order u/s 92CA(3) of the Act passed. 11.09.2023 : Draft assessment order u/s 144C(1)of the Act passed. 30.09.2023 : Limitation for passing the final assessment order-30 month (18 months+12 months) from March 2021 in view of section 153(1) read with section 153(4) of the Act. 24.06.2024 : DRP directions under section 144C

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.

Pricing order u/s 92CA(3) of the Act passed. 25.09.2023 : Draft assessment order u/s 144C(1)of the Act passed. 30.09.2023 : Limitation for passing the final assessment order-30 month (18 months+12 months) from March 2021 in view of section 153(1) read with section 153(4) of the Act. 27.06.2024 : DRP directions under section 144C

BENTLEY SYSTEMS INDIA PRIVATE LIMITED,DELHI vs. DCIT, CIRCLE 4(2), DELHI ASSESSMENT UNIT, INCOME TAX DEPARTMENT, DELHI

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalbentley Systems India Private V Deputy Commissioner Of Limited. Work Well Suites, 10 Floor, S Income Tax, Circle 4(2), C. Max House, 1516/338,339 340 R. Building, Assessment Village Behapur Adjacent Okhla Unit, Income Tax Railway Station, Okhla Industrial Department, Delhi Estate, S.O. Tehkhand, South East Delhi, Delhi, 110020 Pan: Aabcb5645E Appellant Respondent Assessee By Sh. Nishank Vashistha, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 28/01/2026

Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper time limit for completion of assessment proceedings would expire on 30.09.2021. 18. In the present case, the final assessment order passed by the A.O. under Section 143(3) r.w.s. 144C(13) r.w.s. 144B dated 28.07.2022 is clearly beyond the limitation

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

pricing order u/s 92CA(3) of the Act 05.05.2021 : Draft assessment order u/s 144C(1) of the Act passed. 15.02.2022 : DRP directions u/s 144C(15) of the Act issued. 31.12.2020 : Limitation for passing the final assessment order -33 months (21 months + 12 Months) from March 2018 in view of section 153(1) read with Section