PR. COMMISSIONER OF INCOME TAX, CENTRAL-1, DELHI vs. RICHFIELD GOODS PVT. LTD.

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ITA - 177 / 2026HC Delhi11 March 20262 pages
For Petitioner: PUNEET RAI
AI SummaryRemanded

What did the High Court hold?

The High Court admitted the appeal, framing two substantial questions of law. The first question concerns whether the ITAT correctly applied the limitation period of six years for Assessment Year 2013-14, specifically whether the fourth proviso to Section 153A read with Explanation 1 of the Income Tax Act, 1961, was correctly considered. The second question relates to the applicability of an extended limitation period of ten years, given that the proposed additions allegedly exceed Rs. 50 lacs. The Court has not yet decided these issues, as it has only admitted the appeal and issued notice to the respondent. The operative directions are to admit the appeal and issue notice, returnable on 28.04.2026. No finding has been reached on the merits of the case.

What were the facts?

The appeal is filed by the Pr. Commissioner of Income Tax, Central-1, Delhi (Revenue) against an order of the Income Tax Appellate Tribunal (ITAT). The assessee is Richfield Goods Pvt. Ltd. The assessment year in question is 2013-14. The dispute pertains to the limitation period for assessment. The Revenue is challenging the ITAT's decision that the assessment was time-barred. The procedural history indicates that the Revenue has filed this appeal before the High Court, and notice has been issued to the respondent. The High Court has admitted the appeal.

What were the issues?

The High Court framed two substantial questions of law: 1. Whether the Income Tax Appellate Tribunal was justified in holding the assessment to be time-barred, considering the limitation of six years from 13.03.2019 for Assessment Year 2013-14, without taking into account the fourth proviso to Section 153A read with Explanation 1 of the Income Tax Act, 1961? 2. Whether, in the facts and circumstances of the case, the extended period of limitation of ten years would not be available to the Assessing Officer as the addition proposed to be made exceeds Rs. 50 lacs? Contentions: Assessee: The judgment records no arguments for the assessee. Revenue: The Revenue contends that the ITAT erred in not considering the fourth proviso to Section 153A and Explanation 1 of the Income Tax Act, 1961, which might extend the limitation period. The Revenue also argues that an extended period of ten years should be available as the proposed additions exceed Rs. 50 lacs.

Which sections of the Income-tax Act were involved?

Section 153A

AI-generated summary — verify with the full judgment below

Cause title — parties, addresses and appearances
$~57 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 177/2026, CM APPL. 14587/2026 PR. COMMISSIONER OF INCOME TAX, CENTRAL-1, DELHI .....Appellant Through: Mr. Puneet Rai, SSC with Mr. Ashvini Kr., Mr. Rishabh Nangia, JSCs. versus RICHFIELD GOODS PVT. LTD. .....Respondent Through: None. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR

O R D E R %

11.03.

2026

1.

On hearing learned counsel for the appellant, we are of the view that following substantial questions of law arise from the order of the Tribunal : (i) Whether the Income Tax Appellant Tribunal was justified in holding the assessment to be time barred considering the limitation of six years from 13.03.2019 (for Assessment Year 2013-14) without taking into account forth proviso to Section 153A read with explanation 1 of the Income Tax Act, 1961? (ii) Whether in the facts and circumstances of the case, the extended period of limitation of ten years would not be available to the Assessing Officer as the addition proposed to be made exceeds Rs.50 lacs? This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/03/2026 at 11:05:26

2.

Admit.

3.

Issue notice to the respondent through all permissible modes, returnable on 28.04.2026 alongwith ITA 123/2026. DINESH MEHTA, J.

VINOD KUMAR, J. MARCH 11, 2026/ck

This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/03/2026 at 11:05:26

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