INCOME TAX OFFICER, DELHI vs. PANKAJ ENTERPRISES PVT. LTD., NEW DELHI

ITA 4188/DEL/2024Status: DisposedITAT Delhi05 December 2025AY 2015-16Bench: SHRI ANUBHAV SHARMA (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)4 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal found that the notice under Section 148 of the Act, served via email on 01.04.2021 at 7:06 AM, was indeed time-barred. Consequently, the assessment order was liable to be quashed.

What were the facts?

The Revenue appealed against an order of the NFAC, while the assessee filed a Cross Objection. The assessee's primary ground was that the assessment order was invalid due to a time-barred notice under Section 148 of the Income Tax Act.

What were the issues?

Whether the notice under Section 148 of the Income Tax Act, served electronically, was issued within the prescribed limitation period.

Which sections of the Income-tax Act were involved?

Section 147,Section 144B,Section 148,Section 282(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A” BENCH, DELHI

Before: SHRI ANUBHAV SHARMA & SHRI MANISH AGARWAL

For Appellant: Ms. Shilpi Jain, CA
Hearing: 01.12.2025Pronounced: 05.12.2025

Heard together (2 matters)

ITA No. 4188/Del/2024
CO 83/Del/2025

Read from the judgment's own cause title. This page is filed under one of them.

PER ANUBHAV SHARMA, JM:

This appeal is preferred by the Revenue and Cross Objection filed by the assessee against t

The order continues below.

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