DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. DS SPICECO PVT LTD, DELHI
In favour of the assessee: the Revenue's appeal was dismissed. From the AI summary of this appeal.
What did the Tribunal hold?
The Tribunal held that the assessment years in question did not fall within the block period of six assessment years as stipulated in Section 153C of the Act. The Ld.CIT(A) had correctly considered the facts and decided that the assessments could not be made under Section 153C.
What were the facts?
The Revenue preferred appeals against the orders of the Commissioner of Income-tax (Appeals) which had set aside assessments made under Section 153C of the Income Tax Act, 1961. The appeals arose from orders dated 31.03.2023, passed by the DCIT.
What were the issues?
Whether the assessment years involved fall within the six-year block period for invoking Section 153C of the Income Tax Act, 1961. Whether the assessments under Section 153C were validly made.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Cases cited in this judgment(1)Show listHide 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.
- CIT v. RRJ Securities Ltd.689 citing62 Taxmann.com 391 · 2016 · HC · Read judgment
Income Tax Appellate Tribunal, DELHI BENCHES: E : NEW DELHI
Before: SHRI ANUBHAV SHARMA
ORDER PER ANUBHAV SHARMA, JM: These are appeals preferred by the Revenue against the orders dated 14.02.2025 of the Commissioner of Income-tax (Appeals)-24, New Delhi (hereinafter referred to as the ld. First Appellate Authority or ‘the Ld. FAA’ for short) in Appeals No.CIT(A), Delhi-24/10199/2013-14 and No.CIT(A), Delhi- 24/10823/2015-16 arising out of the appeals before it against the orders dated 31.03.2023 passed u/s 153C r.w.s. 143(3) of the Income Tax Act, 1961
ITAs No.3620 & 3621/Del/2025 (hereinafter referred as ‘the Act’) by the DCIT, Central Circle-07, New Delhi (hereinafter referred to as the Ld. AO).
Primarily, the grounds raised by the Revenue appear to be superfluous as the ld.CIT(A), following the decision of the Hon’ble Delhi High Court in CIT v. RRJ Securities Ltd. [2015] 62 taxmann.com 391 (Delhi) and the judgement of the Hon’ble Supreme Court in CIT v. Jasjit Singh (2025) 476 ITR 15, has held that the present two assessment years do not fall in the block period of six assessment years as mentioned in section 153C of the Act. No case of any harmonious interpretation of section 153A of the Act and 153C of the Act is left out to be decided by this bench. The ld.CIT(A) has duly taken into consideration the facts as reflected in the impugned order to hold that the assessments for the years in hand could not have been made by invoking the provisions of section 153C of the Act. Thus there is no substance in grounds. The appeals are dismissed.
More judgments on Section 153C
- Neepaben Sunnybhai Motwani, Rajkot vs Income Tax Officer, RajkotITA 875/RJT/2026[2021-22]Status: Disposed19 Oct 2026AY 2021-22
- Neepaben Sunnybhai Motwani, Rajkot vs The Income Tax Officer, RajkotITA 874/RJT/2026[2020-21]Status: Disposed19 Oct 2026AY 2020-21
- Venish Vinodray Lalani, Rajkot vs Income Tax Officer, MorbiITA 197/RJT/2026[2019-20]Status: Disposed19 Oct 2026AY 2019-20
- Ajay Singh, Kota vs DCIT, Central Circle, KotaITA 495/JPR/2026[2016-17]Status: Disposed13 Oct 2026AY 2016-17
- Dineshkumar Chhaganlal Manavadaria, Junagadh vs ITO Ward 1, JunagadhITA 837/RJT/2025[2020-21]Status: Disposed9 Oct 2026AY 2020-21
Recent GST High Court judgments
Search GST case law →- M/S Rajkalpana Travels PVT. LTD. vs. Commissioner CGST, Delhi North CommissionerateDelhi · 28 Oct 2026
- Mahaveer Ispat Traders vs. Principal Commissioner Dgst Delhi Department Of Trade And Taxes Gnctd & Anr.Delhi · 28 Oct 2026
- Modern Engineers And Contractors vs. The Deputy Assistant Commissioner (St)Andhra Pradesh · 28 Oct 2026
- K Madhusudan Reddy vs. The State Of Andhra PradeshAndhra Pradesh · 28 Oct 2026
- Sandeep Ranjan Rout vs. The Commissioner Of CT And GST, Odisha, KatakOrissa · 28 Oct 2026