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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
Yogesh Kumar, Judicial Member, Krinwant Sahay, Accountant Member
DENSO INDIA PRIVATE LIMITED DELHI – Appellant
Versus
ACIT CIRCLE-7(1) DELHI – Respondent
| Table of Content |
|---|
| 1. appeals challenge time-barred assessment orders. (Para 1 , 2) |
| 2. additional limitation ground admitted as legal issue. (Para 3 , 4) |
| 3. reject deferral; follow coordinate bench precedent. (Para 5 , 6) |
| 4. orders beyond s.153 limit; s.144c inclusive. (Para 7 , 8 , 9) |
| 5. quash orders following binding precedents. (Para 10 , 11 , 12) |
| 6. liberty to revive post-supreme court decision. (Para 13 , 14) |
ORDER
PER KRINWANT SAHAY, AM,
These three 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) all dated 29.04.2022 pertaining to the Assessment Years 2017-18 and 2018-19 respectively.
2. The Assessee raised additional ground No.1 in all the appeals contending that the Final Assessment order all dated 30.04.2022 passed by the A.O. is 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).
3. We have heard both parties and have perused material available on the record. A perusal of substantive ground of appeal and the application for
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