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2026 Supreme(Online)(ITAT) 1488

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
VIVO MOBILE INDIA PRIVATE LIMITED GURGAON – Appellant
Versus
ACIT CIRCLE-25(1) DELHI – Respondent


IN THE INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI BENCH ‘H’ NEW DELHI)

BEFORE YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA No. 1487/DEL/2022 (A.Y. 2017-18) ITA No. 1488/DEL/2022 (A.Y. 2018-19) ITA No. 4408/DEL/2024 (A.Y. 2020-21)

ORDER PER YOGESH KUMAR, U.S. JM:

The captioned appeals are filed by the Assessee challenging the Final Assessment Orders passed u/s 143(3) r.w.s. 144C(13) r.w. Section 144B of the Income Tax Act, 1961 (the Act in short) dated 29/04/2022 pertaining to A.Y 2017-18, 29/04/2022 for A.Y 2018-19 and 31/07/2024 pertaining to the Assessment Year 2020-21 respectively.

2. The Assessee raised Additional Ground contending that the Final Assessment 29/04/2022 pertaining to A.Y 2017-18, 29/04/2022 for A.Y 2018-19 and 31/07/2024 pertaining to the Assessment Year

2020-21 respectivelypassed by the A.O. are time barred by limitation and 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.

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