ITAT Rejects Recall Plea as COVID Limitation Extension Not Apply to Assessment Proceedings

ACIT Vs Rolls Royce India Private Limited (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT), Delhi, dismissed a Miscellaneous Application (MA) filed by the Revenue seeking recall of the Tribunal’s earlier order dated 04.07.2025 in ITA No. 252/Del/2022, which had quashed the final assessment order dated 18.11.2021 as being barred by limitation under Section 144C(13) of the Income-tax Act, 1961. In its earlier order, the Tribunal had observed that Section 144C(13) mandates that once directions are issued by the Dispute Resolution Panel (DRP) under Section 144C(5), the Assessing Officer (AO...