PADMA LOGISTICS PVT LTD,DELHI vs. DCIT, CENTRAL CIRCLE-5, NEW DELHI

ITA 4938/DEL/2025Status: DisposedITAT Delhi11 March 2026AY 2015-16Bench: SHRI CHALLA NAGENDRA PRASAD (Judicial Member), SHRI M. BALAGANESH (Accountant Member)6 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the relevant date for reckoning the block period for Section 153C is the date of the satisfaction note (25-06-2021). Consequently, the six preceding assessment years would commence from AY 2016-17. Therefore, AY 2015-16 was beyond the permissible block period and the proceedings were barred by limitation.

What were the facts?

The assessee challenged the assumption of jurisdiction under Section 153C of the Income Tax Act for AY 2015-16, arguing it was barred by limitation. A search was conducted on Shri Kshitij Lal, and a satisfaction note was recorded for the assessee on 25-06-2021. The AO initiated proceedings under Section 153C based on this, covering AY 2013-14 to 2019-20.

What were the issues?

Whether the initiation of proceedings under Section 153C for AY 2015-16 is barred by limitation, considering the date of the satisfaction note and the relevant block period.

Which sections of the Income-tax Act were involved?

Section 153C,Section 132,Section 153A(1),Section 143(3),Section 148

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Income Tax Appellate Tribunal, DELHI BENCH “C”: NEW DELHI

Before: SHRI CHALLA NAGENDRA PRASAD & SHRI M. BALAGANESH

For Appellant: Shri Raj Kumar Gupta, CA, Shri J. P. Sharma, CA
For Respondent: Shri Dayainder Singh Sidhu, CIT DR
Hearing: 08/01/2026Pronounced: 11/03/2026

PER M. BALAGANESH, A. M.:

1.

The appeal in ITA No.4938/Del/2025 for AY 2015-16, arises out of the order of the ld Commissioner of Income Tax (Appeals)-24, New Delhi [hereinafter referred to as ‘ld. CIT(A)’, in short] dated 04-08-2025 against the order of assessment passed u/s 153C of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 27-03-2023 by the Assessing Officer, DCIT, Central Circle-5, New Delhi (hereinafter referred to as ‘ld. AO’). Padma Logistics Pvt. Ltd

2.

One of the ground raised by the Assessee is challenging the assumption of juri iction under section 153C of the Act for the year under consideration to be flawed as the same would be barred by limitation.

The order continues below.

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