GENINS INDIA INSURANCE TPA LTD,JHANDEWALAN EXTN. vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-28, JHANDEWALAN EXTN.,

ITA 6027/DEL/2025Status: DisposedITAT Delhi09 September 2026AY 2017-20189 pages
AI SummaryAllowed

What were the facts?

The assessee's appeals relate to assessment years 2014-15 to 2020-21, arising from assessment orders passed under Section 153C of the Income Tax Act. The proceedings were initiated based on a search action on another group, and incriminating documents were allegedly found at the searched premises pertaining to the assessee.

What did the Tribunal hold?

The Tribunal held that the proceedings initiated under Section 153C were invalid because the deemed date of search, derived from the satisfaction notes, fell after April 1, 2021. Consequently, the notice issued under Section 153C was quashed, rendering the assessment order invalid.

What were the issues?

The key issue was whether the notice and assessment under Section 153C were validly issued, considering the timing of the deemed search date in relation to the amended provisions of Section 153C(3) and the admissibility of electronic evidence.

Which sections of the Income-tax Act were involved?

Section 153C,Section 153C(1),Section 153C(3),Section 148,Section 65B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH, G: NEW DELHI

Before: SHRI ANUBHAV SHARMA & SMT. RENU JAUHRI

For Appellant: Adv. Sh. Salil Kapoor, Adv, Adv. Ms. Ananya Kapoor, Adv. &
Hearing: 05.08.2026Pronounced: 09.09.2026

Per Bench:-

These captioned appeals are filed by the assessee directed against the orders dated 29.08.2025 of the ld. Commission

The order continues below.

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