ITAT Delhi Judgments — January 2026

The CIT(A) allowed the assessee's ground regarding unexplained investment, holding that the deposits were renewals of old FDs and not fresh investments, and therefore, Section 69 of the Act was not sustainable. The Tribunal found no substance in the revenue's grounds of appeal.

The Tribunal condoned the delay in filing the appeal, acknowledging the circumstances. It was held that the assessee deserves an opportunity to contest the matter on its merits.

The Tribunal held that the assessment order was bad in law as it was completed by an officer who lacked jurisdiction. This was due to the fact that the notice under section 143(2) was issued by a non-jurisdictional Income Tax Officer (ITO), and no valid order for transfer of jurisdiction was placed on record. Relying on various judicial precedents, the Tribunal quashed the assessment order.

The Tribunal held that the final assessment orders in all the appeals were passed beyond the prescribed period of limitation under Section 144C(13) read with Section 153 of the Act. Consequently, the assessment orders were quashed as being without jurisdiction.

The Tribunal held that the provisions of Section 144C and Section 153 of the Income Tax Act are mutually inclusive. The assessment orders passed for both AY 2007-08 and AY 2008-09 were found to be beyond the prescribed period of limitation. Consequently, these assessment orders were quashed.

The Tribunal held that Sections 144C and 153 of the Income Tax Act are mutually inclusive for determining the limitation period for passing the final assessment order. Based on the provided dates, the Tribunal found that the final assessment orders were passed beyond the prescribed time limits.

The Tribunal held that the provisions of section 144C and 153 of the Act are mutually inclusive and interdependent. The period of limitation for passing the final assessment order under section 144C(13) must be determined with reference to section 144C read with section 153. The Tribunal found that the assessment orders were passed beyond the period of limitation.

The Tribunal held that the provisions of Sections 144C and 153 of the Income Tax Act are mutually inclusive, and the period of limitation prescribed under Section 153 is applicable even in cases of remand. The non-obstante clause in Section 144C(13) does not exclude the operation of Section 153. The assessment orders were passed beyond the statutory limitation period.

The Tribunal condoned the delay in filing the appeals after considering the justification provided. The appeals were allowed for statistical purposes, and the issues on merits were restored to the Assessing Officer for a fresh opportunity of hearing.

The Tribunal condoned the delay in filing the appeal, citing adequate justification. The Tribunal noted that the assessee had grounds regarding the opportunity of hearing and that the impugned order was silent on this aspect.

The Tribunal held that Section 144C and Section 153 are mutually inclusive and overlapping. The period of limitation for passing the final assessment order under Section 144C(13) must be determined with reference to Section 153 of the Act. The assessment orders were passed beyond the prescribed limitation period.

The Tribunal, relying on the case of Roca Bathroom Products P. Ltd., held that Sections 144C and 153 of the Act are mutually inclusive and that the time limits for passing final assessment orders must be adhered to. Examining the provided date charts, the Tribunal found that the final assessment orders in all the appeals were indeed passed beyond the period of limitation.

The Tribunal upheld the CIT(A)'s decision, agreeing that the assessments were barred by limitation. The tribunal found that the conditions in the fourth proviso to Section 153A(1) were not met, and the limitation period for issuing notice under Section 153A was restricted to six assessment years prior to the search.

The Tribunal rejected the department's preliminary objection, noting that the Madras High Court's Roca Bathroom Products P. Ltd. judgment, relied upon by the assessees, was not stayed by the Supreme Court. Following this precedent, the Tribunal held that Section 144C(13) must be read along with Section 153 to determine the limitation period. As the final assessment orders were passed beyond this combined statutory period, they were deemed without jurisdiction and consequently quashed.

The Tribunal held that Sections 144C and 153 of the Act are mutually inclusive and that the final assessment order passed for AY 2012-13 was indeed beyond the prescribed period of limitation. Consequently, the assessment order was quashed.

The Tribunal rejected the Revenue's preliminary objection, ruling that Sections 144C and 153 are mutually inclusive for determining limitation. Following the ratio of CIT vs. Roca Bathroom Products P Ltd., it found that the final assessment orders for all impugned assessment years were passed beyond the statutory period of limitation, thus quashing them.

The Tribunal held that the provisions of Section 144C and Section 153 of the Income Tax Act are mutually inclusive and the period of limitation for passing the final assessment order needs to be determined by considering both sections. The Tribunal found that the final assessment orders were indeed passed beyond the stipulated time limits.

The Tribunal held that Section 144C and Section 153 are mutually inclusive and interdependent for determining the limitation period for final assessment orders. The Tribunal found that the final assessment orders in all the relevant assessment years were passed beyond the stipulated deadlines prescribed under Section 153.

The Tribunal held that Sections 144C and 153 are mutually inclusive and interdependent. The period of limitation prescribed under section 153 of the Act is applicable for passing the final assessment order. In all the assessment years under review, the final assessment orders were passed beyond the stipulated deadlines as per section 153.

The Tribunal held that the purchases were duly accounted for, payments were made through regular banking channels from disclosed sources, and the lower authorities had not doubted the source of expenditure. A co-ordinate bench's decision in a similar case was relied upon. The sales were already disclosed as taxable revenue, and treating them as unexplained cash credit amounted to double addition.

The Tribunal held that the approval for the notice under Section 148 was not granted with due application of mind by the PCIT, as it was merely a mechanical endorsement and not reflective of independent consideration. The notice was therefore invalid.

The Tribunal held that the approval for issuing the notice u/s 148A(b) was sought from the Principal Commissioner of Income Tax, whereas as per Section 151 of the Act, approval should have been obtained from the Principal Chief Commissioner or Principal Director General. This procedural lapse vitiates the approval.

The Tribunal held that the CIT(A) correctly deleted the addition, as the AO had failed to consider the established modus operandi of Business Correspondents and Customer Service Providers under their agreement with SBI. The transaction was a bank transfer to a designated settlement account, not an unexplained cash credit.

The Tribunal held that the provisions of Section 144C and Section 153 of the Income Tax Act are mutually inclusive and that the period of limitation prescribed under Section 153 is applicable for determining the validity of the final assessment order under Section 144C. The assessment order was found to be passed beyond the statutory time limit.

The Tribunal held that the provisions of Section 144C and Section 153 are mutually inclusive and overlapping. It found that the final assessment orders in the present cases were indeed passed beyond the period of limitation prescribed under Section 144C(13) r.w.s. 153 of the Act.

The Tribunal held that Sections 144C and 153 of the Income Tax Act are mutually inclusive and interdependent for determining the limitation period for passing final assessment orders. It found that the final assessment orders in the present cases were indeed passed beyond the period of limitation prescribed under these sections.

The Tribunal held that Sections 144C and 153 are mutually inclusive and overlapping. Consequently, the final assessment orders for both assessment years were found to be passed beyond the stipulated limitation period and were quashed. The Revenue's appeal was dismissed as the assessee's appeal was allowed on the ground of limitation.

The Tribunal upheld the CIT(A)'s decision, agreeing that the assessment orders were barred by limitation. The Tribunal noted that a condition under the fourth proviso to Section 153A(1) was not satisfied, and relied on the Delhi High Court's decision in Smart Chip (P) Ltd.

The Tribunal held that Sections 144C and 153 are mutually inclusive for determining the limitation period for final assessment orders. It was found that the final assessment orders in question were passed beyond the statutory time limits, rendering them without jurisdiction.

The Tribunal upheld the CIT(A)'s decision, agreeing that the assessment orders were barred by limitation. It noted that a condition under the fourth proviso to Section 153A(1) was not satisfied, and the period of limitation for issuing notice under Section 153A had to be confined to six assessment years preceding the search year.

The Tribunal held that Sections 144C and 153 are mutually inclusive, and the limitation period for final assessment orders under Section 144C(13) must consider Section 153. It found that the assessment orders were indeed passed beyond the statutory time limits and were consequently without jurisdiction.

The Tribunal held that Sections 144C and 153 are mutually inclusive and the time limits under Section 153 apply to assessment orders passed under Section 144C. The assessment orders in question were found to be passed beyond the stipulated limitation period and were consequently quashed.

The Tribunal held that Sections 144C and 153 of the Act are not mutually exclusive but are mutually inclusive, and the period of limitation for passing the final assessment order must be computed considering both provisions. Following the ratio in Roca Bathroom Products P. Ltd., the Tribunal found that the assessment orders were indeed passed beyond the prescribed limitation and were thus without jurisdiction.

The Tribunal upheld the CIT(A)'s decision, finding that the assessment orders were indeed barred by limitation. It also noted that the conditions stipulated in the fourth proviso to Section 153A(1)(a) were not met, making the grounds of appeal by the Revenue devoid of merit.

The Tribunal held that Section 144C and Section 153 of the Income Tax Act are mutually inclusive, and the time limits prescribed for passing final assessment orders were not adhered to. Consequently, the assessment orders for the impugned assessment years were quashed as being without jurisdiction.

The Tribunal held that Sections 144C and 153 are mutually inclusive for determining the limitation period for final assessment orders. Consequently, assessment orders passed beyond the stipulated time limits are without jurisdiction and thus quashed.

The Tribunal held that the provisions of Section 144C and Section 153 of the Income Tax Act are mutually inclusive and interdependent. Observing that the final assessment orders in question were indeed passed beyond the prescribed period of limitation, the Tribunal concluded that these orders were without jurisdiction.

The Tribunal ruled that Sections 144C and 153 are not mutually exclusive but are interdependent and overlapping. It found that the final assessment orders for the impugned assessment years were passed beyond the prescribed statutory timelines, rendering them invalid.

The Tribunal held that Section 144C and Section 153 are mutually inclusive, not exclusive, and that assessment orders passed beyond the prescribed limitation period are without jurisdiction. The appeals were decided following the ratio of the Roca Bathroom Products P. Ltd. case.

The Tribunal admitted additional evidence filed by the assessee, which appeared relevant, and restored the issue to the Assessing Officer for fresh consideration of these evidences. The assessee had failed to substantiate its claims before the lower authorities.

The Tribunal held that Section 144C and Section 153 of the Income Tax Act are mutually inclusive. The final assessment orders passed by the AO in these cases were beyond the limitation period stipulated under Section 144C(13) read with Section 153 of the Act, rendering them without jurisdiction.

The CIT(A) held the assessment orders to be barred by limitation, relying on the decision in Smart Chip (P) Ltd. The Tribunal found that the condition in clause (a) of the fourth proviso to Section 153A(1) was not satisfied, and thus the grounds of appeal of the Revenue were rejected.

The Tribunal held that Section 144C and Section 153 of the Income Tax Act are mutually inclusive for determining limitation periods. It found that the assessment orders were passed beyond the stipulated timeframes, rendering them without jurisdiction and therefore quashed them, following the precedent set in the Roca Bathroom Products P. Ltd. case.

The Tribunal held that Sections 144C and 153 are mutually inclusive and interdependent for determining the period of limitation. Examining the dates, the Tribunal found that the final assessment orders in both years were passed beyond the stipulated deadlines under the relevant sections.

The Tribunal held that Section 144C and Section 153 of the Act are mutually inclusive and interdependent. The final assessment orders in question were found to be passed beyond the prescribed period of limitation, rendering them without jurisdiction.

The Tribunal held that the approval granted under Section 153D of the Act for the search assessments was indeed mechanical and lacked due application of mind by the approving authority. This was evidenced by consolidated approvals granted for multiple cases and assessment years without adequate scrutiny.

The Tribunal held that Section 144C and Section 153 are mutually inclusive and overlapping, and the time limits prescribed in both sections must be adhered to for passing final assessment orders. It found that the final assessment orders in question were indeed passed beyond the statutory period of limitation.

The Tribunal held that Sections 144C and 153 of the Income Tax Act are mutually inclusive and interdependent. It found that the final assessment orders for both assessment years were passed beyond the period of limitation prescribed by the Act. Consequently, the assessment orders were quashed.

The Tribunal held that Sections 144C and 153 of the Income Tax Act, 1961, are mutually inclusive and interdependent. The assessment orders passed in these cases were found to be beyond the stipulated time limits prescribed under Section 153, rendering them invalid.

The Tribunal held that the provisions of Sections 144C and 153 are mutually inclusive, not exclusive. The final assessment orders for the assessment years 2007-08 and 2008-09 were found to be passed beyond the period of limitation prescribed by Section 144C(13) read with Section 153 of the Act.