TILLSOIL FARMS PRIVATE LIMITED,DELHI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT, DELHI

ITA 2454/DEL/2026Status: DisposedITAT Delhi09 September 2026AY 2013-1410 pages
AI SummaryAllowed

What were the facts?

The assessee purchased agricultural land for a significant sum, but declared a lower value for fixed assets in its return. The Assessing Officer made an addition for the difference, which was confirmed by the CIT(A). The assessee appealed, raising grounds related to jurisdiction, time-barred notices, and the nature of the receipt.

What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 of the Income Tax Act, 1961, was barred by limitation, following Supreme Court judgments. Consequently, the reassessment proceedings initiated based on this notice were quashed.

What were the issues?

The key issues were whether the reassessment proceedings were initiated based on a time-barred notice under Section 148 and whether the addition made on account of forfeiture of advance money was justified.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 144B,Section 250,Section 271(1)(c),Section 148A,Section 148,Section 149,Section 51,Section 56(2)(ix),Section 151A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH ‘C’, NEW DELHI

Before: Sh. Raj Kumar Chauhan&

For Appellant: CA &
Hearing: 31.08.2026Pronounced: 09.09.2026

Per Raj Kumar Chauhan, Judicial Member:

The appeal of the assessee is directed against the order dated 08.01.2026 of ld. CIT(A)/NFAC, Delhi passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) wherein the appeal against the best judgment Assessment Order u/s 147 r.w.s. 144 r.w.s. 144B of the Act dated 10.05.2023 was dismissed.

2.

Facts in brief as culled out from the orders of the authorities below are that the assessee company filed its return of income for A.Y. 2013-14 declaring income of Rs.49,31,568/-. During the assessment proceedings, it was noticed that the assessee had purchased agricultural land at Village Ghaber,

2 Tillsoil Farms Pvt.

The order continues below.

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