PREETI CHADHA vs. INCOME TAX OFFICER, WARD 62(1), DELHI & ORS.

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W.P.(C)/579/2024HC DelhiDLHC01000945202429 September 2026Bench: HON'BLE DR. JUSTICE ADITI CHOUDHARY,HON'BLE MR. JUSTICE DINESH MEHTA3 pages
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What did the High Court hold?

The Delhi High Court held that the impugned notice dated 25.07.2022, issued under Section 153C of the Income-Tax Act, 1961, for assessment year 2014-15, was time-barred. The Court reasoned that the satisfaction note was recorded on 16.06.2022, and the notice was issued on 25.07.2022. Calculating the limitation period backward from the immediately preceding financial year (2021-22) or assessment year (2022-23) relative to the satisfaction note date, and considering the escaped income was less than Rs. 50,00,000/-, the notice fell outside the permissible six-year period. The Court found this position to be in line with the plain reading of Sections 153A and 153C of the Act and the precedent set in Ojjus Medicare Pvt. Ltd. (supra). Consequently, the writ petition was allowed, and the notice was quashed.

What were the facts?

The petitioner, Preeti Chadha, challenged a notice dated 25.07.2022 issued under Section 153C of the Income-Tax Act, 1961, for assessment year 2014-15. This notice was issued in furtherance of a satisfaction note recorded by the Assessing Officer on 16.06.2022. The petitioner contended that the notice was issued beyond the prescribed time period under Section 153A read with Section 153C of the Act, as it prevailed for assessment year 2014-15. The Revenue, represented by Mr. Vipul Agrawal, could not dispute the facts but mentioned that an SLP was filed against a relevant High Court judgment before the Supreme Court.

What were the issues?

1. Whether the notice dated 25.07.2022 issued under Section 153C of the Income-Tax Act, 1961, for assessment year 2014-15 is beyond the prescribed time period, considering the satisfaction note was recorded on 16.06.2022? Assessee's contention: 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 for assessment year 2014-15. They relied on the judgment of this Court in Principal Commissioner of Income Tax-1 (Central-1) v. Ojjus Medicare Pvt. Ltd. ([2024] 465 ITR 101 (Delhi)). Revenue's contention: The Revenue, while not disputing the facts, 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

W.P.(C) 579/2024 Page 1 of 3

$~12 * IN THE HIGH COURT OF DELHI AT NEW DELHI Date of decision: 29th September, 2026 # CNR No. DLHC010009452024 + W.P.(C) 579/2024 & CM APPL. 2580/2024

PREETI CHADHA

.....Petitioner Through: Ms. Ananya Kapoor and Mr. Utkarsa Gupta, Advocates.

versus

INCOME TAX OFFICER, WARD 62(1), DELHI & ORS. .....Respondents Through: Mr. Vipul Agrawal, SSC with Ms. Sakshi Shairwal, Mr. Akshat Singh, JSCs.

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 25.07.2022 issued under Section 153C of the Income-Tax Act, 1961 (hereinafter referred to as ‘Act of 1961’) in furtherance of the satisfaction note dated 16.06.2022 recorded by the Assessing Officer for assessment year 2014-15. 2. Learned Counsel for the petitioner at the outset argued that the impugned notice has been passed beyond the time period prescribed under Digitally Signed By:NAVEEN KUMAR Signing Date:01.10.2026 19:50:40 Signature Not Verified

W.P.(C) 579/2024 Page 2 of 3

Section 153A read with Section 153C of the Act of 1961, as prevailing at the relevant time (AY 2014-15). 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 16.06.2022, i.e. in the assessment year 2023-24, the notice passed on 25.07.2022 qua assessment year 2014-15 is clearly beyond the limitation period (which shall be 6 years as the escaped income is less than Rs.50,00,000/-), if calculated backward from immediately preceding year from the relevant assessment year i.e. 2023-24, which means financial year 2021-22 or assessment year 2022-23. For ease of understanding, a tabular depiction is made hereunder: Year No. (counted backwards) Assessment Year 1 AY 2022-23 2 AY 2021-22 3 AY 2020-21 4 AY 2019-20 5 AY 2018-19 Digitally Signed By:NAVEEN KUMAR Signing Date:01.10.2026 19:50:40 Signature Not Verified

W.P.(C) 579/2024 Page 3 of 3

6th year AY 2017-18

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 25.07.2022 is quashed. Pending application stands disposed of.

(DINESH MEHTA) JUDGE

ADITI CHOUDHARY (JUDGE) SEPTEMBER 29, 2026/ck Digitally Signed By:NAVEEN KUMAR Signing Date:01.10.2026 19:50:40 Signature Not Verified

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