PCIT DELHI-7 vs. UK PAINTS INDIA PRIVATE LIMITED

ITA - 525 / 2022HC Delhi12 December 20223 pages

For Petitioner: SUNIL KUMAR AGARWAL

AI SummaryDismissed

What did the High Court hold?

The High Court noted that the proceedings in question were for AY 2006-2007, which fell outside the determined block assessment period. The court found the issue to be covered by its previous judgment in CIT v. RRJ Securities Ltd.

What were the facts?

The revenue appealed against an ITAT order that determined the block assessment period for the assessee. The ITAT and CIT(A) ruled that the block assessment period spanned from AY 2008-2009 to AY 2013-2014.

What were the issues?

The key issue was to determine the correct block assessment period. The court had to decide if AY 2006-2007 was within the relevant block assessment period.

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(1)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

CIT v. RRJ Securities Ltd.
380 ITR 612 · 2016 · HC · Read judgment
689 citing

$~66 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 525/2022&CM Appl.53642/2022

PCIT DELHI-7

..... Appellant Through: Mr Sunil Agarwal, Sr. Standing Counsel with Mr Tushar Gupta & Mr Utkarsh Tiwari, Advs.

versus

UK PAINTS INDIA PRIVATE LIMITED ..... Respondent

Through: Mr Udit Naresh, Adv.

CORAM:

HON'BLE MR JUSTICE RAJIV SHAKDHER

HON'BLE MS JUSTICE TARA VITASTA GANJU

O R D E R %

12.12.2022 [Physical Hearing/Hybrid Hearing (as per request)] CM Appl.53643/2022 1. Allowed, subject to just exceptions. CM Appl.53642/2022 2. This is an application filed on behalf of the appellant/revenue seeking condonation of delay in filing the present appeal. 3. The delay, according to the appellant/revenue, is 47 days. 4. For the reasons given in the application, the delay is condoned. 5. The application is disposed of in the aforesaid terms. ITA 525/2022 6. This appeal is directed against order dated 13.05.2022 passed by the

ITA 525/2022

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This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/03/2026 at 14:03:41

Income Tax Appellate Tribunal [in short “Tribunal”]. 7. The short issue which arises for consideration is, as to what would be the block assessment period. 8. The record reveals that the satisfaction note was generated on 08.10.2013. 9. The Tribunal and the Commissioner of Income Tax(Appeals) [in short “CIT(A)”] have ruled, that the block assessment vis-a-vis the respondent/ assessee period spanned between AY 2008-2009 to AY 2013-2014. 10. Proceedings in this case against the respondent/assessee were taken out qua AY 2006-2007 which is beyond the block assessment period relevant to the respondent/assessee as per the conclusion reached by the Tribunal and the CIT(A). 11. In reaching their conclusion, the Tribunal and CIT(A) has relied upon the judgment of this court in CIT v. RRJ Securities Ltd. (2016) 380 ITR 612 (Del). 12. In view of the facts noted above, the issue raised in this appeal is covered. 13. The appeal is accordingly closed. 14. At this stage, Mr Sunil Agarwal, who appears on behalf of the appellant, however informs us that the appellant/revenue has preferred a petition with the Supreme Court against the aforementioned judgment. 14.1 Needless to add, parties will abide by the final decision in the appellant/revenue’s appeal.

ITA 525/2022

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15.

Given the aforesaid position, the instant appeal is closed, with the observation made hereinabove.

RAJIV SHAKDHER, J

TARA VITASTA GANJU, J

DECEMBER 12, 2022/r

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ITA 525/2022

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