Delhi High Court Admits Revenue's Appeal on Applicability of Section 153 Limitation to Section 144C Assessments

Overview of the Judicial Pronouncement

The Hon'ble Delhi High Court has agreed to examine a critical legal controversy regarding the statutory time limits applicable to final assessment orders in transfer pricing cases. In the matter of PCIT Vs Rohde And Schwarz India Pvt Ltd, the Revenue department approached the judiciary via an appeal under Section 260A of the Income Tax Act 1961. The department has challenged a previous ruling delivered by the Income Tax Appellate Tribunal (ITAT), which had decided the limitation issue in favor of the assessee.

Procedural History and Delay Condonation

Before delving into the substantive legal arguments, the High Court addressed the procedural formalities associated with the filing. The Revenue had submitted an application seeking the condonation of a 14-day delay in re-filing the appeal before the bench.