M/S ENERGY DEVELOPMENT COMPANY LIMITED,WEST BENGAL, KOLKATA vs. DCIT /ACIT CENTRAL CIRCLE-2, GURGAON, HARYANA, GURGAON

ITA 2109/DEL/2026Status: DisposedITAT Delhi23 September 2026AY 2019-2030 pages
AI SummaryAllowed

What were the facts?

The assessee filed appeals against assessment orders passed under Section 153A following a search. The assessee argued that assessments for certain years were beyond the permissible block period, lacked jurisdiction due to unsatisfied provisos, or were time-barred. No incriminating material was found during the search.

What did the Tribunal hold?

The Tribunal held that the assessment for AY 2011-12 was beyond the permissible block period under Section 153A. It also found that additions for AYs 2013-14 and 2014-15 did not constitute 'assets' as defined, and that assessments for unabated years lacked incriminating material. The assessment for AY 2020-21 was found to be barred by limitation.

What were the issues?

Whether assessments under Section 153A were validly made within the prescribed block period and time limits, and if additions were based on incriminating material found during the search.

Which sections of the Income-tax Act were involved?

Section 153A,Section 153B,Section 143(3),Section 56(2)(viia),Section 56(2)(x)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH ‘B’: NEW DELHI

Before: SHRI S.RIFAUR RAHMAN & MS. MADHUMITA ROY

For Appellant: Shri Ved Jain, CA, Ms. Kanishka Garg, CA, Shri Aayush Garg, CA, Ms. Bulbul Singhal, CA
For Respondent: Shri Om Prakash, CITDR
Hearing: 05.08.2026Pronounced: 23.09.2026

PER S.RIFAURRAHMAN,AM:

1.

These appeals are filed by the assesseeagainst the order passed by the ld. Commissioner of Income-tax (Appeals)-3, Gurgaon [for short ‘ld. CIT (A)] dated 17.09.2026 and dated 21.11.2025 for the Assessment Years 2011-12, 2013-14 to 2020-21. 2. Since the issues are common and the appeals are connected, hence the same are heard together and being disposed off by this common order.

3.

At the time of hearing, ld. AR of the assessee with the permission of the Bench brought to our notice relevant facts on record and his submissions. He submi

The order continues below.

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