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2026 Supreme(Online)(ITAT) 1491

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
MSD PHARMACEUTICALS PVT LTD DELHI – Appellant
Versus
DCIT CIRCLE -16(1) NEW 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. 530/DEL/2022 (A.Y. 2017-18)

ITA No. 2330/DEL/2022 (A.Y. 2018-19) ITA No. 4571/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 28/01/2022 pertaining to A.Y 2017-18, dated 28/07/2022 for A.Y 2018-19 and dated 03/08/2024 for the Assessment Year 2020-21 respectively.

2. The Assessee raised Additional Grounds of Appeal No. 6, 10 and 34 for the Appeals filed for A.Y 2017-18 to 2020-21 respectively contending that the Impugned Final Assessment orders passed by the A.O. are time barred by limitation and are bad in law, as the same have 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 Produ

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