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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
Vikas Awasthy, Judicial Member, Sanjay Awasthi, Accountant Member
The Bank of Tokyo-Mistubishi UFJ Ltd. – Appellant
Versus
Deputy Commissioner of Income-Tax – Respondent
| Table of Content |
|---|
| 1. cross appeals against assessment order under section 144c. (Para 1) |
| 2. assessee argues assessment barred by limitation per 144c r.w.s 153. (Para 2) |
| 3. revenue objects to hearing due to pending supreme court reference. (Para 3) |
| 4. tribunal rejects revenue's objection to proceed with hearing. (Para 4) |
| 5. revenue argues 144c independent timelines exclude section 153. (Para 5) |
| 6. sections 144c and 153 mutually inclusive for limitation. (Para 6 , 7) |
| 7. timeline shows assessment order beyond limitation period. (Para 8) |
| 8. assessment quashed; appeals disposed on jurisdictional ground. (Para 9 , 10 , 11 , 12 , 13) |
आदेश/ORDER
PER VIKAS AWASTHY, JM:
These cross appeals by the assessee and the Revenue for AY 2012-13 are directed against the Assessment Order dated 10.05.2016 passed u/s.143(3) r.w.s. 144C(13) of the Income Tax Act,1961(hereinafter referred to as ‘the Act’). The assessee in appeal has challenged validity of the final assessment order on the ground of limitation under section 144C(13) r.w.s. 153 of the Act. The assessee has raised this legal ground by way of additional ground of appeal vide application dated 26.05.2023.
2. The ld. Counsel for the assessee placing reliance
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