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

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

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

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

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

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

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

AVAYA INDIA PRIVATE LIMITED,MUMBAI vs. ASSESSING OFFICER, NFAC, NOT AVAILABLE

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

TOYOTA BOSHOKU DEVICE INDIA PRIVATE LIMITED ,GURGAON, HARYANA vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT, GURGAON, HARYANA

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

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

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

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

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

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

260A. (4) Where the order of 29[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the order of the Appellate Tribunal, as the case may be, referred to in sub- section (1) is not in conformity with the final decision on the question of law in the other case, as and when such order is received, the Principal Commissioner

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

260A. (4) Where the order of 29[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the order of the Appellate Tribunal, as the case may be, referred to in sub- section (1) is not in conformity with the final decision on the question of law in the other case, as and when such order is received, the Principal Commissioner

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.

260A. (4) Where the order of 29[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the order of the Appellate Tribunal, as the case may be, referred to in sub- section (1) is not in conformity with the final decision on the question of law in the other case, as and when such order is received, the Principal Commissioner

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.

260A. (4) Where the order of 29[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the order of the Appellate Tribunal, as the case may be, referred to in sub- section (1) is not in conformity with the final decision on the question of law in the other case, as and when such order is received, the Principal Commissioner