I HOME AND INFRASTRUCTURE PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 28, DELHI, DELHI

ITA 1914/DEL/2026Status: DisposedITAT Delhi19 August 2026AY 2015-169 pages
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What were the facts?

Proceedings under Section 153C were initiated against the assessee based on documents found during a search on a third-party group. The key issue was the validity of jurisdiction for assessment years 2014-15, 2015-16, and 2016-17, particularly concerning the date of search initiation and the applicability of Section 153C(3).

What did the Tribunal hold?

The Tribunal held that for assessment years 2014-15 and 2015-16, the assessments were barred by limitation as they fell outside the 6-year block period from the deemed date of search. For assessment year 2016-17, proceedings under Section 153C were quashed as the deemed date of search fell after April 1, 2021, making Section 153C(3) inapplicable.

What were the issues?

Whether the Assessing Officer validly assumed jurisdiction under Section 153C for the relevant assessment years, considering the deemed date of search and the applicability of Section 153C(3) which restricts its application for searches initiated on or after April 1, 2021.

Which sections of the Income-tax Act were involved?

Section 132,Section 153C,Section 153C(3),Section 147,Section 148

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH “B”: NEW DELHI

Before: SHRI M. BALAGANESH & SHRI SUDHIR KUMAR

For Respondent: Ms. Sugandha Sharma, CIT(DR)
Hearing: 10.08.2026Pronounced: 19.08.2026

PER M. BALAGANESH, A. M.:

These appeals of the assessee arises out of the order passed by the Commissioner of Income Tax, Appeal, Delhi-25 [hereinafter referred to as ‘ld. CIT(A)’, in short] in Appeal Nos. 1913 to 1915/Del/2026 for A.Ys. 2014- 15 to 2016-17 even dated 12.12.2025 which in turn arises out of the order passed by the Assessing Officer, DCIT, Circle-28, Delhi (hereinafter referred to as ‘ld. AO’) passed u/s 153C of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) dated e

The order continues below.

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