ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-25, DELHI, DELHI vs. RRG ENTERPRISES PRIVATE LIMITED(ERSTWHILE ULIKE HOLDINGS PVT. LTD.), DELHI

आदेश / ORDER

SHRI M. BALAGANESH, ACCOUNTANT MEMBER 1. The appeal in ITA Nos.3985 & 3985/Del/2026 for AYs 2012-13 and 2013-14, arises out of the order of the ld National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as ‘ld. CIT(A)’, in short] dated 03.12.2025 against the order of assessment passed u/s 153C of the Income- tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 12.03.2024 for AY 2012-13 and 15.03.2024 for AY 2013-14 by the Assessing Officer, ACIT, 1 Central Circle-25, Delhi (hereinafter referred to as ‘ld. AO’). Identical issues are involved in both these appeals and hence they are taken up together and disposed of by this common order for the sake of convenience.

The first identical issue to be decided in these appeals is as to whether 2. the years under consideration fall outside the block period and accordingly no assessment could be validly framed thereon in the facts and circumstances of the instant case. This is a preliminary issue going to the root of the matter and hence we proceed to take up the same first for adjudication.

We have heard the rival submissions and perused the materials 3. available on record. The search operation u/s 132 of the Act was carried out on 18.10.2019 in Alankit Group of cases. Certain documents belonging to/ pertaining to/ relating to assessee were found in the said search and accordingly the seized documents were handed over by the AO of the searched person to the AO of the assessee on 05.04.2022. Hence, the date of search qua the assessee becomes 05.04.2022 falling in AY 2023-24 in view of the decision of the Hon'ble Supreme Court in the case of CIT vs Jasjit Singh reported in 458 ITR 437 (SC). Hence, the block period of 6 years or 10 years, as the case may be, need to be reckoned from AY 2023-24, being the year of search for the assessee and not based on the search date of originally searched person (i.e. Alankit Group). This issue is no longer res integra in view of the decision of the Hon’ble Jurisdictional Delhi High Court in the case of PCIT Vs. Ojjus Medicare Pvt. Ltd reported in 161 taxmann.com 160 (Del HC). Applying the principles laid down by the Hon'ble Delhi High Court, the ld CIT(A) had computed the block period as under:-

Computation of ten-years block Number of period as provided u/s. Years 153Cr.w.s. 153A of the Act. A.Y. 2023-24 1 A.Y. 2022-23 2 A.Y. 2021-22 3 A.Y. 2020-21 4 A.Y. 2019-20 5 A.Y. 2018-19 6 A.Y. 2017-18 7 A.Y. 2016-17 8 A.Y. 2015-16 9 A.Y. 2014-15 10 Hence, the years under consideration i.e. AY 2012-13 and 2013-14 4. would fall outside the block period and no valid assessments could be framed thereon u/s 153C of the Act. Hence, we do not find any infirmity in the order of the ld CIT(A) in quashing the assessment as time barred and void ab initio.

Since the assessment is quashed in the abovementioned terms, the 5. adjudication of other grounds raised by the revenue become academic in nature and they are left open.

In the result, both the appeals of the revenue are dismissed. 6.

Order pronounced in the open court on 21st -Sep-2026.

-Sd/- -Sd/- SUDHIR KUMAR M. BALAGANESH JUDICIAL MEMBER ACCOUNTANT MEMBER Delhi Dated: 21/09/2026 AK Keot Copy to: ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-25, DELHI, ROOM NO. 317 3RD FLOOR ARA CENTRE 1 JHANDEWALAN EXTENSION DELHI 110055, NEW DELHI-110055, DELHI RRG ENTERPRISES PRIVATE LIMITED(ERSTWHILE ULIKE HOLDINGS PVT. LTD.), 2 G-80 GROUND FLOOR, PHASE-I ASHOK VIHAR, DELHI-110052, NEW DELHI-110052, DELHI 3 THE PCIT / CIT, 4 THE D.R., ITAT, DELHI BENCH 5 GUARD FILE