DEVEN CHACHRA,NEW DELHI vs. ACIT, CIRCLE -22(2), NEW DELHI

ITA 2415/DEL/2026Status: DisposedITAT Delhi24 August 2026AY 2015-1610 pages
AI SummaryAllowed

What were the facts?

The assessee filed an appeal against the order upholding the determination of income at Rs. 11,73,89,328/-. The assessee contended that the reassessment proceedings initiated under Section 147 were barred by limitation.

What did the Tribunal hold?

The Tribunal held that the notices issued under Section 148 of the Act beyond 31.03.2022 were barred by limitation. Consequently, the reassessment proceedings and the consequent demands were quashed.

What were the issues?

The primary issue was whether the reassessment proceedings initiated under Section 147 were barred by limitation, considering the amended provisions and the applicability of the Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 148A,Section 149,Section 151,Section 151A,Section 10(35),Section 234B,Section 234C,Section 234D

AI-generated summary — verify with the full judgment below

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

For Appellant: Shri Ankit Kumar, Advocate
For Respondent: Shri G.P. Singh, Sr. DR
Hearing: 02.07.2026Pronounced: 24.08.2026

PER S.RIFAUR RAHMAN,AM:

1.

This appeal is filed by the assessee against the order passed by the ld. Commissioner of Income-tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi dated 16.02.2026 for the Assessment Year 2015-16 raising following grounds of appeal :-

“1. That the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi has erred both in law and, on facts in upholding the determination of income made by the learned Assessment Unit, Income Tax Department of the appellant at Rs. 11,73,89,328/- as against declared income of Rs.4,10,24,650/- in an order of assessment dated 27.05.2023 u/s 147 of the Act read with section 144B of the Act.

2

2.

That the lea

The order continues below.

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