Qualcomm India Pvt Ltd,New Delhi vs Acit Circle 19 (1) , New Delhi on 30 January, 2026
20569-20572/2023 therefore, deciding the very same issue by this
Tribunal at this stage would be premature, thus submitted that the
3 ITA Nos. 537, 2374 & 4412/Del/2024
Qualcomm India Private Limited Vs. ACIT
Tribunal cannot decide the issue of limitation in terms of the ratio laid
down by the Hon'ble High Court of Madras in the case of Roca
Bathroom Products (P) Ltd. (supra). Accordingly, the Ld. Department's
Representative sought for deferral of adjudication of the present
Appeal and also the issue of limitation. The Ld. Department's
Representative has also filed detail written submission.