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2026 Supreme(Online)(ITAT) 1746

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
FUJITSU CONSULTING INDIA PRIVATE LIMITED NEW DELHI – Appellant
Versus
ACIT CIRCLE-7(1) DELHI – Respondent


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

BEFORE YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI KRINWANT SAHAY, ACCOUNTANT MEMBER ITA No.1508 /DEL/2022 (A.Y. 2017-18) ITA No.1698/DEL/2022 (A.Y. 2018-19) ITA No.3878/DEL/2024 (A.Y. 2020-21)

ORDER PER YOGESH KUMAR, U.S. JM:

The captioned appeals are filed by the Assessees challenging the respective 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 30/04/2022 pertaining to A.Y 2017-18, dated 30/05/2022 for A.Y

2018-19 and 30/09/2023 pertaining to A.Y 2020-21 respectively.

2. The Assessees have raised Additional Ground No. 14in A.Y 2017- 18, Additional Ground No 14 in A.Y 2018-19 and Ground No. 1.1 in A.Y 2020-21 contending that the impugned Final Assessment orders 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 Products (P.)

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