SRI SAT SAHIB HOUSING AND INFRASTRUCTURE DEVELOPMENT COMPANY,GURGAON vs. DCIT/ACIT CC-31, NEW DELHI, DELHI

ITA 3114/DEL/2025Status: DisposedITAT Delhi28 January 2026AY 2009-10Bench: SHRI CHALLA NAGENDRA PRASAD (Judicial Member), SHRI BRAJESH KUMAR SINGH (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the date of recording satisfaction by the AO of the non-searched person is considered the date of search. Based on Supreme Court and High Court decisions, the assessment proceedings for AYs 2008-09 to 2010-11 were found to be beyond the permissible ten-year block.

What were the facts?

A search and seizure operation was conducted on 14.09.2017. The assessee's appeals challenge the validity of assessment orders passed under Section 153C for Assessment Years 2008-09 to 2010-11, arguing they are time-barred due to the deemed date of search.

What were the issues?

Whether the assessment proceedings under Section 153C for the Assessment Years 2008-09, 2009-10, and 2010-11 are barred by limitation as they fall outside the ten-year block from the deemed date of search.

Which sections of the Income-tax Act were involved?

Section 153C,Section 143(3),Section 132

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Income Tax Appellate Tribunal, DELHI BENCH, H: NEW DELHI

Before: SHRI CHALLA NAGENDRA PRASAD & SHRI BRAJESH KUMAR SINGH

For Appellant: Shri Ujjawal Chaudhary, CA(Virtual)
For Respondent: Shri Dayainder Singh Sidhu, CIT(DR)
Hearing: 19.01.2026Pronounced: 28.01.2026

PER

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