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

BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER ITA No. 972/DEL/2025 (A.Y. 2022-23)

Eleentec Co. Ld. Vs. Deputy/Assistant

37 Samsung-RO268 Beon-Gil Director of Income Tax, Yeongtong-GU, Gyeonggi DO International Taxation, Republic of Korea Noida, Uttar Pradesh PAN: AAFCE6530P Appellant Respondent Assessee by Sh. Himanshu S. Sinha, Adv, Sh.

Prashant Mehar Chandani, Adv& Sh.

Jainender Singh Kataria, Adv Revenue by Sh. M.S. Nethrapal, CIT DR Date of Hearing 19/08/2025 Date of Pronouncement 28/08/2025 ORDER PER YOGESH KUMAR, U.S. JM:

This appeal is filed by the assessee pertaining to Assessment Year

2022-23 challenging the Final Assessment Order passed by Deputy Commissioner of Income Tax DDIT/ADIT, International Taxation, Nodia dated 20/01/2025 u/s143(3) r.w. Section 144C(13) of the Income Tax Act, 1961 ('Act' for short).

2. The grounds of Appeal are as under:-

“1. That on the facts and circumstances of the case and in law, the Ld. AO has erred in passing the assessment order dated January 20, 2025, beyond the prescribed limitation period under Section 153(1) of the Income-tax Act