PR. COMMISSIONER OF INCOME TAX, CENTRAL-1, DELHI vs. RICHFIELD GOODS PVT. LTD.

On hearing learned counsel for the appellant, we are of the view that following substantial questions of law arise from the order of the Tribunal : (i) Whether the Income Tax Appellant Tribunal was justified in holding the assessment to be time barred considering the limitation of six years from 13.03.2019 (for Assessment Year 2013-14) without taking into account forth proviso to Section 153A read with explanation 1 of the Income Tax Act, 1961? (ii) Whether in the facts and circumstances of the case, the extended period of limitation of ten years would not be available to the Assessing Officer as the addition proposed to be made exceeds Rs.50 lacs? 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 11:05:26

Admit.

Issue notice to the respondent through all permissible modes, returnable on 28.04.2026 alongwith ITA 123/2026. DINESH MEHTA, J.