RAMAKRISHNA ELECTRO COMPONENTS PRIVATE LIMITED vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 19 1 DELHI & ORS.

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W.P.(C)/298/2026HC DelhiDLHC01000311202629 September 2026Author: HON'BLE MR. JUSTICE DINESH MEHTA,HON'BLE DR. JUSTICE ADITI CHOUDHARY3 pages
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What did the High Court hold?

The High Court held that the impugned notice dated 19.03.2025 issued under Section 153C for assessment year 2012-13 was clearly beyond the limitation period. The Court reasoned that the satisfaction note was recorded on 15.03.2025, which falls within assessment year 2025-26. Calculating backwards, even if the escaped income was more than Rs. 50,00,000/- (implying a 10-year limitation period), the notice issued in AY 2025-26 for AY 2012-13 would be time-barred. The Court found the issue squarely covered by its own judgment in Principal Commissioner of Income Tax-1 (Central-1) v. Ojjus Medicare Pvt. Ltd. The writ petition was allowed, and the notice dated 19.03.2025 was quashed. The ratio decidendi is that a notice under Section 153C issued beyond the prescribed limitation period, as determined by the date of satisfaction note and the relevant assessment year, is invalid. The operative direction was to quash the notice.

What were the facts?

The petitioner, Ramakrishna Electro Components Private Limited, filed a writ petition challenging a notice dated 19.03.2025 issued under Section 153C of the Income-Tax Act, 1961. This notice was issued in furtherance of a satisfaction note dated 15.03.2025 recorded by the Assessing Officer for assessment year 2012-13. The petitioner contended that the notice was issued beyond the time period prescribed under Sections 153A and 153C of the Act for the relevant assessment year. The revenue acknowledged that an SLP was filed against a similar judgment but could not dispute the facts involved in the present case. The High Court noted that the satisfaction note was recorded in assessment year 2025-26, making the notice for assessment year 2012-13 time-barred.

What were the issues?

1. Whether the notice dated 19.03.2025 issued under Section 153C of the Income-Tax Act, 1961, for assessment year 2012-13 is barred by limitation, considering the satisfaction note was recorded on 15.03.2025. Assessee's Contentions: The petitioner argued that the impugned notice was passed beyond the time period prescribed under Section 153A read with Section 153C of the Act of 1961, as prevailing at the relevant time (AY 2012-13). They relied on the judgment of this Court in Principal Commissioner of Income Tax-1 (Central-1) v. Ojjus Medicare Pvt. Ltd. reported in [2024] 465 ITR 101 (Delhi). Revenue's Contentions: The revenue could not dispute the facts involved but submitted that an SLP against the Ojjus Medicare Pvt. Ltd. judgment had been filed before the Hon'ble Supreme Court.

Which sections of the Income-tax Act were involved?

Section 153C,Section 153A

AI-generated summary — verify with the full judgment below

Cause title — parties, addresses and appearances
W.P.(C) 298/2026 Page 1 of 3 $~34 * IN THE HIGH COURT OF DELHI AT NEW DELHI Date of decision: 29th September, 2026 # CNR No. DLHC010003112026 + W.P.(C) 298/2026, CM APPL. 1406/2026, CM APPL. 1407/2026 RAMAKRISHNA ELECTRO COMPONENTS PRIVATE LIMITED .....Petitioner Through: Mr. Ved Jain, Mr. Nischay Kantoor & Ms. Vandana Kothari, Advocates. versus ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 19 1 DELHI & ORS. .....Respondents Through: Mr. Vipul Agrawal, SSC with Ms. Sakashi Shairwal, JSC, Mr. Gaoraang Ranjan & Ms. Harshita Kotru, Advs. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE DR. JUSTICE ADITI CHOUDHARY

J U D G M E N T DINESH MEHTA, J. (ORAL)

1.

By way of present writ petition preferred under Article 226 of the Constitution of India, the petitioner has challenged the notice dated 19.03.2025 issued under Section 153C of the Income-Tax Act, 1961(hereinafter referred to as ‘Act of 1961’) in furtherance of the satisfaction note dated 15.03.2025 recorded by the Assessing Officer for assessment year 2012-13. W.P.(C) 298/2026

2.

Learned Counsel for the petitioner at the outset argued that the impugned notice has been passed beyond the time period prescribed under Section 153A read with Section 153C of the Act of 1961, as prevailing at the relevant time (AY 2012-13).

3.

He submitted that the issue involved in the present writ petition is squarely covered by judgment of this Court rendered in the case of Principal Commissioner of Income Tax-1 (Central-1) v. Ojjus Medicare Pvt. Ltd. reported in [2024] 465 ITR 101 (Delhi).

4.

Mr. Vipul Agrawal, learned Senior Standing Counsel for the Department could not dispute the aforesaid position of facts involved. He, however, submitted that an SLP against the said judgment has been filed before Hon’ble the Supreme Court.

5.

Heard learned counsel for the parties.

6.

It does not need much discussion that as the satisfaction note was recorded on 15.03.2025, i.e. in the assessment year 2025-26, the order passed on 19.03.2025 qua assessment year 2012-13 is clearly beyond the limitation period (which shall be 10 years as the escaped income is more than Rs.50,00,000/-), if calculated backward from assessment year 2025-26. For ease of understanding, a tabular depiction is made hereunder: Year No. (counted backwards) Assessment Year 1 AY 2025-26 2 AY 2024-25 3 AY 2023-24 4 AY 2022-23 5 AY 2021-22 W.P.(C) 298/2026

6 AY 2020-21 7 AY 2019-20 8 AY 2018-19 9 AY 2017-18 10th year AY 2016-17

7.

The impugned notice is, thus, time-barred on a plain reading of Sections 153A and 153C of the Act of 1961 so also in light of Ojjus Medicare Pvt. Ltd. (supra)).

8.

The writ petition is allowed, the notice dated 19.03.2025 is quashed. Pending application stands disposed of.

(DINESH MEHTA) JUDGE

ADITI CHOUDHARY (JUDGE) SEPTEMBER 29, 2026/nk

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