GOODYEAR INDIA LIMITED,HARYANA V. JAO - ASSISTANT COMMISSIONER OF INCOME TAX (OSD), DELHI, NEW DELHI

SA 100/DEL/2026

AI Insights

The case involves Goodyear India Limited, which filed a stay application concerning an outstanding tax demand of Rs. 20,49,96,560. The Tribunal had previously granted stays on the recovery of this demand, which were set to expire. The current application sought an extension of this stay. The Tribunal considered the ongoing legal proceedings, specifically the referral of a legal issue to the Supreme Court, which contributed to the delay in the appeal's disposal. The Tribunal decided to extend the stay, recognizing that the delay was not due to the assessee's actions.

• Counselvise Citation: [2026] 140 COUNSELVISE.COM (IT) 842145 (ITAT-DELHI)
• Duration Of Justice: 7 day(s)
• Appeal Type: Stay Application
• Pronouncement Date: 24-02-2026
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: I
• Assessment Year: 2021-2022
• Appeal Filed On: 17-02-2026
• Other Referred Cases: ACIT Vs. Shelf Drilling Ron Tappmeyer Ltd. in Special Leave to Appeal
• Laws Referred To: Section 144C, Section 153
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: AMIT KUMAR SINGH
• Assessee Lawyers: NEERAJ JAIN; RAMIT KATIYAL
• Keywords: Application of stay; Extension of stay

Judgement Text

" IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘H’ NEW DELHI BEFORE SHRI YOGESH KUMAR U.S, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER S. A NO. 100/Del/2026 in (ITA No. 5212/Del/2024 ( A.Y 2021-22) Goodyear India Limited Mathura Road, Ballabhgarh, Fariday-121004 PAN: AAACG3511H (APPLICANT) Vs JAO-ACIT (OSD) New Delhi (RESPONDENT) ORDER PER YOGESH KUMAR, U.S. JM: By way of this, the present Stay Application, Assessee sought for Extension of Stay on recovery of outstanding demand aggregating to Rs. 20,49,96,560/-. 2. We have heard the parties and perused the material. The Co- ordinate Bench of the Tribunal vide order dated 21/02/2025 in S.A No. 79/Del/2025, stayed the outstanding demand for a period of 180 days from the date of the order or till the disposal of ITA No. 5212/Del/2024 whichever is earlier. Further, Assessee filed one more Stay Application No. 425/Del/2025 and vide order dated 22/08/2025, the Tribunal extended the Stay of recovery on outstanding demand for Appellant by Mr.Neeraj Jain, Adv, Mr.Ramit Katiyal, CA, Mr. Dhruv Seth, Adv & Ms.Mansha Bhalla, CA Respondent by Sh. Amit Kumar Singh, Sr. DR Date of Hearing 20.02.2026 Date of Pronouncement 24.02.2026 Printed from counselvise.com further period of 180 days or till the date of Appeal whichever is earlier. 3. Considering the fact that one of the issues involved in the main Appeal i.e. issue of limitation arising from the interplay between Section 144C and Section 153 of the Act is presently referred to Larger Bench of the Hon'ble Supreme Court in the case of ACIT Vs. Shelf Drilling Ron Tappmeyer Ltd. in Special Leave to Appeal, the delay in disposal of the Appeal before us is not attributable to the Assessee. Therefore, we hereby grant extension of stay of recovery on outstanding demand for a period of 180 days or till disposal of Appeal, whichever is earlier. 6. In the result, stay application filed by the assessee is allowed. Order pronounced in the Open Court on this 24th Day of February, 2026. Sd/- Sd/- (NAVEEN CHANDRA) (YOGESH KUMAR U.S.) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 24/02/2026 R. Naheed * Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT ASSISTANT REGISTRAR ITAT NEW DELHI Printed from counselvise.com Printed from counselvise.com "