PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

ITA 2709/DEL/2025Status: DisposedITAT Delhi04 February 2026AY 2014-1550 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings for AY 2012-13 were time-barred. The CIT(A) had correctly quashed the reassessment order on the grounds of limitation, as the notice under Section 148 was issued beyond the permissible period.

What were the facts?

Following a search and seizure operation, the Assessing Officer (AO) reopened assessments for multiple years, including AY 2012-13, based on alleged undisclosed sales. The AO made additions by estimating profits on these undisclosed sales.

What were the issues?

The key issue was whether the reassessment proceedings for AY 2012-13 were initiated within the time limits prescribed by Section 149 of the Income Tax Act, considering the date of the search and the issuance of the notice under Section 148.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 149,Section 153C

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Cases cited in this judgment(12)Show list

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

Before: SHRI ANUBHAV SHARMA & SHRI MANISH AGARWAL

The captioned appeals are filed by Assessee and Revenue against the separate orders, all are dated 28.02.2025 passed by Ld. Commissioner of Income Tax (Appeals)-30, New Delhi [‘Ld. CIT(A)' in short] u/s 250 of the Income Tax Act, 1961 ['the Act'] arising

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