IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘I’: NEW DELHI BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA No.940/Del/2023 (ASSESSMENT YEAR 2018-19)

Asst. CIT, Adidas India Marketing Circle-1(1), Private Limited Vs. Delhi.

Office No.6, 2^nd Floor, Sector B, Plot No.11, Vasant Kunj, South West, Delhi-110070.

PAN-AAACA5313P (Appellant) (Respondent)

Assessee by Dr. Shashwat Bajpai, Adv.

Department by Sh. Dharam Veer Singh, CIT-DR Date of Hearing 03/03/2025 Date of Pronouncement 12/03/2025

O R D E R

PER MANISH AGARWAL, AM:

This appeal is filed by the assessee against the final order passed u/s 143(3)/144C(13) of the Income Tax Act, 1961 (the Act, in short) by the Asst. Commissioner of Income Tax, Circle 1(1), Delhi (referred to as AO) dated 28/02/2023 vide DIN & letter No. ITBA/COM/F/17/2022-23/1050225372(1) for the Assessment Year

2018-19.

2. The assessee has challenged the final order by raising the following grounds of appeal:

“1. Final assessment order is void-ab-initio, bad in law and barred by limitation

1.1. On the facts and circumstances of the case and in law, the final assessment order dated February 28, 2023 passed by the learned Assistant C