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 on the decision rendered in the case of CIT vs. Roca Bathroom Products P Ltd. reported as 140 taxmann.com 304 (Mad.), submits that the assessment order in the impugned assessment year is barred by limitation. He submitted that for determining the period of limitation for passing final assessment order the provisions of section 144C of the Act, are to be read with section 153 of the Act. He furnished the date chart tabulating the relevant dates for ascertaining the period of limitation within which the final assessment order was required to be passed and also the dates on which the final assessment orders for respecti