DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. PRIYANKA GUPTA (LEGAL HEIR OF LATE SMT. NEERU GUPTA), DELHI

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ITA 2839/DEL/2025Status: DisposedITAT Delhi04 February 2026AY 2021-221 pages

In favour of the assessee: the Revenue's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the CIT(A) correctly followed binding judicial precedents from the Delhi High Court. The grounds raised by the Revenue lacked substance, and the appeal was dismissed.

What were the facts?

The Revenue appealed an order of the CIT(A) which granted relief to the assessee. The assessee's relief was based on Delhi High Court judgments regarding the reckoning of the block period for assessments when the assessee is not the subject of a search.

What were the issues?

Whether the CIT(A) erred in following binding precedents regarding the reckoning date for the block period of assessments in a non-search case.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(1)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, “B” BENCH, DELHI

Before: SHRI ANUBHAV SHARMA&

For Appellant: CA Sh. HarshitSrivastav, CA
For Respondent: Ms. Pooja Swaroop, CIT, DR
Hearing: 14.01.2026Pronounced: 04.02.2026

This appeal is preferred by the Revenue against the order dated 29.01.2025 of the Ld. CIT(A)-30, New Delhi (hereinafter referred as Ld.

First Appellate Authority or in short Ld. ‘FAA’) in DIN No :

P a g e | Priyanka Gupta(legal heir of late smt.Neeru Gupta) (AY: 2021-22) ITBA/APL/M/250/2024-25/1072691622(1)arising out of the order dated 30.12.2022 u/s 144 r.w.s143(3) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) passed by the DCIT, CC-31 for AY: 2021-22.

2.

On hearing both sides we find that the department has come up in appeal challenging the impugned order of ld. First Appellate Authority where assesse got relief on the basis of judgments of Hon’ble Delhi High Court in the case of PCIT vs. Ojjus Medicare Pvt. Ltd. in dated 03.04.2024and in the case of PCIT Vs. Shri Jasjit Singh (2024) 336 CTR 634 (Delhi). The issue culminated in favour of the assessee as ld. First Appellate Authority has held that in regard to present Assessment Year 2020-21 on the basis of search assessment in the case of assessee being of none search person, therefore, the date of search to reckon block period of assessments has to be calculated from the date of receipt of the books.

3.

We are of the considered view that there is no law cited to the contrary in the ground as raised the challenge to allege that ld. CIT(A) erred in P a g e | Priyanka Gupta(legal heir of late smt.Neeru Gupta) (AY: 2021-22) following the binding decision in case of Ojjus (supra) or Jasjit Singh (supra).

Grounds raised have no substance.The appeal of revenue is dismissed.

Order pronounced in the open court on 04.02.2026

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