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

ITA 2713/DEL/2025Status: DisposedITAT Delhi04 February 2026AY 2018-1950 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings for AY 2012-13 were time-barred. It referred to the Supreme Court's decision in Rajiv Bansal, emphasizing that the proviso to Section 149(1)(b) limits the retrospective operation of the amended section and protects assessees from reopening assessments beyond the old time limits.

What were the facts?

The assessee, engaged in furniture manufacturing and interior designing, had its premises searched. Subsequently, reassessment proceedings were initiated under Section 147 for AY 2012-13, with the Assessing Officer estimating profits on undisclosed sales. The CIT(A) quashed the reassessment order on grounds of limitation.

What were the issues?

The primary issue was whether the reassessment proceedings initiated under Section 147 for AY 2012-13 were within the prescribed time limits, considering the amendments to Section 149 of the Income Tax Act.

Which sections of the Income-tax Act were involved?

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

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(4)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

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

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 147

All 49,210 judgments and leading authorities on Section 147 →

Recent GST High Court judgments

Search GST case law →