JSP PROJECTS (P) LTD,DELHI vs. DCIT CENTRAL CIRCLE - 13, DELHI

ITA 3647/DEL/2025Status: DisposedITAT Delhi09 March 2026AY 2021-22Bench: SHRI YOGESH KUMAR U.S. (Judicial Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the date of receipt of seized documents by the Assessing Officer of the 'other person' is the deemed date of search for the purposes of Section 153C. Assessments made without adhering to this and other procedural requirements were quashed.

What were the facts?

The assessee filed appeals against assessment orders passed under section 153A/153C. A key issue was the assumption of jurisdiction by the Assessing Officer under Section 153C without sufficient incriminating material and proper reckoning of the limitation period.

What were the issues?

Whether the Assessing Officer validly assumed jurisdiction under Section 153C without incriminating material and whether the limitation period was correctly calculated based on the date of receipt of documents.

Which sections of the Income-tax Act were involved?

Section 153C,Section 143(3),Section 68,Section 69C,Section 127(2),Section 65B

AI-generated summary — verify with the full judgment below

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

Before: SHRI YOGESH KUMAR U.S.

For Appellant: Shri Ved Jain, Adv, Ms. Uma Upadhyay, CA
For Respondent: Ms. Rajinder Kaur, CIT-DR
Hearing: 26.02.2026Pronounced: 09.03.2026

PER AMITABH SHUKLA, AM,

This bunch of five appeals filed by the assessee is against order all dated 25.03.2025 of the learned Commissioner of Income Tax(Appeals)-25, New Delhi, [hereinafter referred to as ‘ld. CIT(A)] arising out of respective assessment orders passed under section 153A/153C and 143(3) of the Income Tax Act, 1961 pertaining to Assessment Years 2015-16, 2016-17, 2019-20, 2020-21 and 2021-22, respectively. The word ‘Act’ herein this order would mean Income Tax Act, 1961. ITA Nos.3643 to

The order continues below.

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