DCIT, NEW DELHI vs. PARVINDER SINGH GAHLAUT, VASANT KUNJ

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI [ DELHI BENCH: “A” NEW DELHI] BEFORE SHRI YOGESH KUMAR U.S, JUDICIAL MEMBER AND SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER ITA No. 8971/DEL/2025 ( A.Y 2014-15) ITA No. 8972/DEL/2025 ( A.Y 2015-16) Deputy Commissioner of Vs Parvinder Singh Gahlot Income Tax, C-9/9156 Vasant Kunj South E-2, Block ARA Centre, West Delhi, New Delhi Jhandewalan Extension, PAN: AACPG7488C New Delhi (APPLICANT) (RESPONDENT) C.O. No. 70/Del/2026 in ITA No. 8971/DEL/2025 C.O. No. 68/Del/2026 in ITA No. 8972/DEL/2025

Parvinder Singh Gahlot Vs Deputy Commissioner of C-9/9156 Vasant Kunj South Income Tax, West Delhi, New Delhi E-2, Block ARA Centre, PAN: AACPG7488C Jhandewalan Extension, (APPLICANT) New Delhi

(RESPONDENT)

Appellant by Sh. Vinod Bindal, CA & Ms. Rinky Sharma, ITP, Sh. Anmol Jha, Adv Respondent by Sh. Jitender Singh, CIT DR

Date of Hearing 23.04.2026 Date of Pronouncement 29.04.2026

ORDER PER YOGESH KUMAR, U.S. JM: The captioned Appeals are filed by the Revenue challenging the

orders of Ld. Commissioner of Income Tax (Appeals)-Delhi-23 (‘Ld.

CIT(A)’ for short), dated 14/10/2025, for the Assessment Year 2014-

15 and 2015-16 respectively, wherein the Ld. CIT(A) has allowed the

Appeals of the Assessee. The Assessee has also filed above Cross

Objections by challenging the orders impugned for rejecting certain

legal grounds raised by the Assessee.

years 2014-15 and 2-15-16 are time barred in view of the settled

position of law declared by Hon’ble High Court of Delhi in the case of

Ojjus Medicare Pvt Ltd. (2024) 161 taxmann.com 160 (Delhi) dated

03/04/2024 as the satisfaction note u/s 153C of the Act was recorded

on 29/09/2021 (relevant to A.Y 2022-23) and 6 AYs backward end at

(1) A.Y 2016-17, (2) A.Y 2017-18, (3) A.Y 2018-19, (4) A.Y 2019-20, (5)

A.Y 2020-21 and (6) A.Y 2021-22 (F.Y 2020-21) as the satisfaction

note u/s 153C was not recorded for an extended period of 10 AYs.

Thus, sought for allowing the C.O. No. 70/Del/2026 and C.O.

68/Del/2026 and dismissal of the Appeals filed by the Revenue.

allowing the Appeals in ITA No. 8971/Del/2025 and 8972/Del/2025

and dismissal of C.Os filed by the Assessee.

case, the satisfaction note under Section 153C of the ACT was record

on 29/09/2021 (relevant to A.Y 2022-23) and 6 AYs backward years

A.Y 2016-17, A.Y 2017-18, A.Y 2018-19, A.Y 2019-20, A.Y 2020-21

and A.Y 2021-22 (F.Y 2020-21). Considering the fact that as the

satisfaction note u/s 153C was not recorded for an extended period of

10 Assessment Years, by following the ratio laid down by the Hon’ble

High Court of Delhi in the case of Ojjus Medicare Pvt. Ltd.(2024) 161

reported in taxmann.com 160 (Delhi) dated 03/04/2024, the

Assessment Years under consideration i.e. A.Y 2014-15 and 2015-16

are time barred; accordingly, the subject assessment years are hereby

quashed. The C.O. No. 70/Del/2026 and C.O. 68/Del/2026 filed by

the Assessee are allowed.

and 2015-16 by allowing Cross Objections filed by the Assessee, the

Appeals in ITA Nos. 8972/Del/2025 and 8971/Del/2025 filed by the

Revenue are dismissed for having become in-fructuous.

Order pronounced in the Open Court on this 29th Day of April, 2026

Sd/- Sd/- (SANJAY AWASTHI) (YOGESH KUMAR U.S.) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 29/04/2026 R. Naheed * Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT

ASSISTANT REGISTRAR ITAT NEW DELHI