GURSHARAN GOYAL ,DELHI vs. DCIT CIRCLE-27, DELHI

ITA 5992/DEL/2025Status: HeardITAT Delhi05 March 2026AY 2011-12Bench: SHRI MAHAVIR SINGH (Vice President), SHRI S. RIFAUR RAHMAN (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the assessment under Section 153A for AY 2011-12 was barred by limitation because the assessment year did not fall within the six assessment years preceding the year in which the search was conducted (AY 2018-19).

What were the facts?

The assessee filed an appeal against the assessment order for AY 2011-12. The assessment was framed under Section 153A of the Income Tax Act, 1961. A search and seizure operation was conducted on the assessee on 06.07.2017.

What were the issues?

Whether the assessment framed under Section 153A for AY 2011-12 is barred by limitation as it falls outside the six preceding assessment years from the search year.

Which sections of the Income-tax Act were involved?

Section 153A,Section 132,Section 127(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH “G’’ : NEW DELHI

Before: SHRI MAHAVIR SINGH & SHRI S. RIFAUR RAHMAN

For Appellant: Shri C.S. Agarwal, Sr. Adv., Shri Atul Puri, CA, Shri Umashankar, Adv. & Shri R.P. Mall, Adv
For Respondent: Shri Mahesh Kumar, CIT(DR)
Hearing: 02.03.2026Pronounced: 02.03.2026

PER MAHAVIR SINGH, VP:

This appeal has been filed by the Assessee against the order dated 2.9.2025 passed by the Ld. Commissioner of Income Tax (Appeals-29) (hereinafter referred as CIT(A)), New Delhi for the assessment year 2011-12 in appeal no. CIT(A), Delhi-29. Assessment was framed by the DCIT, CC-27, New Delhi vide order dated 31.12.2019 u/s. 153A of the Income Tax Act, 1961 (hereinafter referred as the Act).

2.

At the outset, Ld. Counsel for the assessee, Shri C.S. Agarwal, Senior Advocate argued that the assessment framed by the DCIT-CC-27, New Delhi for the assessment year 2011-12 u/s. 153A of the Act is barred by l

The order continues below.

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