2025 (12) TMI 621

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....('Act' for short) by Deputy Commissioner of Income Tax, Circle -13(1)- Delhi dated 15/05/2022 & 18/05/2022 respectively. 2. Both the appeals are pertaining to single assessee and identical contentions are raised by the Ld. Senior Counsel Sh. Ajay Vohra appearing for Assessee's Representative. Therefore, both the Appeals of the Assessee are decided in this common order. For the sake of convenience, brief facts of the case for A.Y 2017-18 has been considered which are as under:- Assessee filed return of income for A.Y 2017-18 at Rs. 1,66,06,01,330/, which has been processed by CPC on the returned income. The case of the Assessee was selected under CASS and notices were issued which have been replied by the Assessee. Co....

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....) of the Act on 18/05/2022, wherein the Ld. A.O. assessed the total income of the Assessee at Rs. 2,33,54,82,920/- as against declared income of Rs. 2,31,92,15,760/-. 4. Aggrieved by the final assessment orders dated 15/05/2022 for Assessment Year 2017-18 and 18/05/2022 for Assessment Year 2018-19, Assessee preferred the captioned Appeals. 5. The Ld. Counsel for the Assessee at the outset submitted that the final assessment orders have been passed beyond the time limit specified u/s. 144C (13) of the Act, therefore, the impugned assessment orders deserves to be set aside by the Tribunal. The Ld. Counsel for the Assessee relied on following judicial pronouncements:- a) Louis Dreyfus Company India (P.) Ltd. vs. DCIT [2024] 159 ....

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....ich are beyond the limitation prescribed u/s. 144C(13) of the Act. The Ld. Assessee's Representative has filed the date chart reflecting the dates and events/particulars in both the years which is reproduced as under:- 8. As per Section144C(13) of the Act, upon receipt of direction issued under Sub Section (5) of Section 144C by the DRP, the A.O. shall inconformity with the directions, complete, the assessment within one month from the end of month in which such direction received. For the sake of convenient Section 144C(13) is reproduced as under:- "Section 144C(13) : Upon receipt of direction issued under Sub Section (5), the Assessing Officer, shall, in conformity with the directions complete, notwithstanding any....