CIT v. RRJ Securities Ltd.

380 ITR 612High Court2016#80 most cited

What is CIT v. RRJ Securities Ltd. authority for?

Completed assessments can be interfered with under Section 153A or 153C only on the basis of incriminating material unearthed during the search, necessitating a direct correlation between the discovered material and the power to assess or reopen concluded assessments.

689

judgments rely on this decision, according to BharatTax’s citation analysis of 367,518 Indian tax judgments — from 2015 to 2026.

Also referred to as

CIT v. RRJ Securities Ltd. · Section 153A · Section 153C · incriminating material · reopening completed assessments · correlation between discovered material and assessment · power to assess · validity of search assessments · block assessment · satisfaction note

Also reported as

62 Taxmann.com 3912015 SCC OnLine DEL 13085128 DTR 57

Sections most often in play

Section 153CSection 143(3)Section 153ASection 132Section 148Section 147Section 151Section 149
Read the full judgment

Issues it is cited on

section 153atosection 153b(1)(a)abatement of assessmentsection 153(c)(1)section 153c(1)section 153c proceedingssection 153(c)section 153b(1)section 113section 158bdblock periodsatisfaction note

Judgments citing CIT v. RRJ Securities Ltd.

Alankit Forex India Limited, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4213/DEL/2025[2018-19]Status: DisposedITAT Delhi28 Nov 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…ther held that completed assessments could be interfered with only on the basis of incriminating material unearthed during the course of search. 13. The issue came to be examined in greater detail in CIT v. RRJ Securities Ltd. [2015] 62 taxmann.com 391/[2016] 380 ITR 612/2015 SCC Online Del 13085. Dealing with the imperatives of a correlation between the material discovered in the course of a search and the power to assess or reopen concluded assessments, in RRJ Securities, the Court held:- "33. The record slip belongs to the assessee and, therefore, the action of the Assessing Officer of the searched persons rec…

Alankit Forex India Limited, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4212/DEL/2025[2017-18]Status: DisposedITAT Delhi28 Nov 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…ther held that completed assessments could be interfered with only on the basis of incriminating material unearthed during the course of search. 13. The issue came to be examined in greater detail in CIT v. RRJ Securities Ltd. [2015] 62 taxmann.com 391/[2016] 380 ITR 612/2015 SCC Online Del 13085. Dealing with the imperatives of a correlation between the material discovered in the course of a search and the power to assess or reopen concluded assessments, in RRJ Securities, the Court held:- "33. The record slip belongs to the assessee and, therefore, the action of the Assessing Officer of the searched persons rec…

Alankit Forex India Limited, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4211/DEL/2025[2016-17]Status: DisposedITAT Delhi28 Nov 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…ther held that completed assessments could be interfered with only on the basis of incriminating material unearthed during the course of search. 13. The issue came to be examined in greater detail in CIT v. RRJ Securities Ltd. [2015] 62 taxmann.com 391/[2016] 380 ITR 612/2015 SCC Online Del 13085. Dealing with the imperatives of a correlation between the material discovered in the course of a search and the power to assess or reopen concluded assessments, in RRJ Securities, the Court held:- "33. The record slip belongs to the assessee and, therefore, the action of the Assessing Officer of the searched persons rec…

Alankit Forex India Limited, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4210/DEL/2025[2015-16]Status: DisposedITAT Delhi28 Nov 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…ther held that completed assessments could be interfered with only on the basis of incriminating material unearthed during the course of search. 13. The issue came to be examined in greater detail in CIT v. RRJ Securities Ltd. [2015] 62 taxmann.com 391/[2016] 380 ITR 612/2015 SCC Online Del 13085. Dealing with the imperatives of a correlation between the material discovered in the course of a search and the power to assess or reopen concluded assessments, in RRJ Securities, the Court held:- "33. The record slip belongs to the assessee and, therefore, the action of the Assessing Officer of the searched persons rec…

Alankit Forex India Limited, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4209/DEL/2025[2014-15]Status: DisposedITAT Delhi28 Nov 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…ther held that completed assessments could be interfered with only on the basis of incriminating material unearthed during the course of search. 13. The issue came to be examined in greater detail in CIT v. RRJ Securities Ltd. [2015] 62 taxmann.com 391/[2016] 380 ITR 612/2015 SCC Online Del 13085. Dealing with the imperatives of a correlation between the material discovered in the course of a search and the power to assess or reopen concluded assessments, in RRJ Securities, the Court held:- "33. The record slip belongs to the assessee and, therefore, the action of the Assessing Officer of the searched persons rec…

Alankit Forex India Limited, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4208/DEL/2025[2013-14]Status: DisposedITAT Delhi28 Nov 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…ther held that completed assessments could be interfered with only on the basis of incriminating material unearthed during the course of search. 13. The issue came to be examined in greater detail in CIT v. RRJ Securities Ltd. [2015] 62 taxmann.com 391/[2016] 380 ITR 612/2015 SCC Online Del 13085. Dealing with the imperatives of a correlation between the material discovered in the course of a search and the power to assess or reopen concluded assessments, in RRJ Securities, the Court held:- "33. The record slip belongs to the assessee and, therefore, the action of the Assessing Officer of the searched persons rec…

ACIT, New Delhi vs. Vrinda Farms Private Limited, Delhi

In the result, appeal of the revenue is dismissed and the CO of the assessee is dismissed as infructuous

ITA 4694/DEL/2024[2012-13]Status: DisposedITAT Delhi28 Nov 2025AY 2012-13

Bench: Shri M. Balaganesh & Ms Madhumita Royacit, Vs. Vrinda Farms Pvt. Ltd, Central Circle-4 43, Community Centre, New Delhi Sakir Nagar So, New Friends Colony So, South East Delhi (Appellant) (Respondent) Pan: Aaacv0355L Co-10/Del/2025 (In Ita No. 4694/Del/2024) (Assessment Year: 2012-13) Vrinda Farms Pvt. Ltd, Vs. Acit, 43, Community Centre, Central Circle-4 Sakir Nagar So, New New Delhi Friends Colony So, South East Delhi (Appellant) (Respondent) Pan: Aaacv0355L

For Appellant: Shri Biren Shah, CA (though VC)For Respondent: Shri Dayainder Singh Sindhu, CIT DR
Section 132Section 143(3)Section 147Section 148Section 149Section 149(1)Section 153ASection 153CSection 153C(1)

…isdictional High Court has referred to the decision in the case of Ojju Medicare Pvt. Ltd. (Supra). The Hon'ble Delhi High Court in the case of Ojjus Medicare Pvt. Ltd. (Supra) has considered its earlier decision in the case of M/s. RRJ Securities Ltd. [2016] 380 ITR 612(Delhi) dated 30.10.2015 wherein the Hon'ble Court had held as under:- "the date of handing over of material, will be construed as the reference date for initiation of action u/s 153C of the Act, as against date of initiation of search, construed the reference date for initiation of action u/s 153A of the Act. Vrinda Farms Pvt. Ltd 17. Thus, in v…

DCIT Central Circle-28, New Delhi vs. M/S Okaya Power Private Limited, New Delhi

Appeal is dismissed, in above terms

ITA 4357/DEL/2025[2012-13]Status: DisposedITAT Delhi27 Nov 2025AY 2012-13

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal`

For Appellant: Sh. S. S. Nagar, CAFor Respondent: Sh. Jitender Singh, CIT-DR
Section 132(1)Section 143(3)Section 153CSection 3

…t would be pertinent to refer to the position of law as laid down by the earlier decisions of the Hon’ble Supreme Court in the case of CIT v. Jasjit Singh [2023] 458 ITR 437 (SC) and the Hon’ble Delhi High Court in the case of CIT v. RRJ Securities Ltd [2016] 380 ITR 612 (Delhi) with regard to the date of reckoning for calculating the assessment years for reopening in the case of a non-searched person/third party, wherein it was observed that as against the date of search, the date on which the AO of the person other than the one searched assumes the possession of the seized assets would be the relevant date for…

Revelation Unique Retail and Marketing Private Limited, Delhi vs. Assistant Commissioner of Income Tax, Central Circle-3, Delhi

In the result, the appeal filed by the assessee is allowed

ITA 466/DEL/2025[2019-20]Status: DisposedITAT Delhi26 Nov 2025AY 2019-20

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2019-20 Revelation Unique Retail & Vs. Assistant Commissioner Of Income Marketing Private Ltd., Tax, Central Circle-3, 5A/3A, Ansari Road, Daryaganj, Delhi New Delhi Pin: 1100 02 Pan :Aaicr9933L (Appellant) (Respondent)

Section 115BSection 127Section 132Section 142(1)Section 153CSection 234BSection 234CSection 250Section 272A(1)(d)Section 274

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘B’ NEW DELHI BEFORE SHRI S RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI VIMAL KUMAR, JUDICIAL MEMBER Assessment Year: 2019-20 Revelation Unique Retail and Vs. Assistant Commissioner of Income Marketing Private Ltd., Tax, Central Circle-3, 5A/3A, Ansari Road, Daryaganj, Delhi New Delhi PIN: 1100 02 PAN :AAICR9933L (Appellant) (Respondent) Assessee by Shri Pranshu Goel, CA and Shri Aditya Gupta, Adv. Department by Shri Kailash Dan Ratnoo, CIT(DR) Date of hearing 28.08.2025 Date of pronouncement 26.11.2025 ORDER PER VIMAL KUMAR, JUDICIAL MEMBER: The appeal filed…

Anshul Bansal, Delhi vs. Assistant Commissioner of Income Tax Central Circle 3, Delhi

In the result, the appeal filed by the assessee is allowed

ITA 465/DEL/2025[2019-20]Status: DisposedITAT Delhi26 Nov 2025AY 2019-20

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2019-20 Ansul Bansal, Vs. Assistant Commissioner Of Income 5A/3A, Ansari Road, Daryaganj, Tax, Circle-3, New Delhi Delhi Pin: 1100 02 Pan :Auqpb8298M (Appellant) (Respondent)

Section 127Section 132Section 142(1)Section 143(2)Section 153CSection 250Section 272A(1)(d)Section 274Section 53CSection 69A

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘B’ NEW DELHI BEFORE SHRI S RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI VIMAL KUMAR, JUDICIAL MEMBER Assessment Year: 2019-20 Ansul Bansal, Vs. Assistant Commissioner of Income 5A/3A, Ansari Road, Daryaganj, Tax, Circle-3, New Delhi Delhi PIN: 1100 02 PAN :AUQPB8298M (Appellant) (Respondent) Assessee by Shri Pranshu Goel, CA and Shri Aditya Gupta, Adv. Department by Shri Kailash Dan Ratnoo, CIT(DR) Date of hearing 28.08.2025 Date of pronouncement 26.11.2025 ORDER PER VIMAL KUMAR, JUDICIAL MEMBER: The appeal filed by the assessee is against order dated 09.01.20…

DCIT CC 2 2, Chennai vs. Southern Agrifurane Industries Pvt Ltd, Chennai

In the result, both the both the appeals filed by the Revenue and the Revenue and the

ITA 1254/CHNY/2025[2014-15]Status: DisposedITAT Chennai21 Nov 2025AY 2014-15

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Mrs. C. Yamuna, CIT &
Section 132Section 153CSection 250

…(Supra) settles the issue and holds this to be an Education Society (Supra) settles the issue and holds this to be an essential requirement. The decision of thi essential requirement. The decision of this Court in CIT s Court in CIT-7 Vs RRJ Securities (2016) 380 ITR 612 (Del) and ARN Infrastructure India Ltd. es (2016) 380 ITR 612 (Del) and ARN Infrastructure India Ltd. es (2016) 380 ITR 612 (Del) and ARN Infrastructure India Ltd. Vs ACIT [2017] 394 ITR 569 (Del) a Vs ACIT [2017] 394 ITR 569 (Del) also held that in order to justify the lso held that in order to justify the assumption of Jurisdiction under sectio…

Southern Agrifurane Industries Pvt. Ltd., Chennai vs. ACIT, Central Circle-2(2), Chennai

In the result, both the both the appeals filed by the Revenue and the Revenue and the

ITA 1238/CHNY/2025[2017-18]Status: DisposedITAT Chennai21 Nov 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Mrs. C. Yamuna, CIT &
Section 132Section 153CSection 250

…(Supra) settles the issue and holds this to be an Education Society (Supra) settles the issue and holds this to be an essential requirement. The decision of thi essential requirement. The decision of this Court in CIT s Court in CIT-7 Vs RRJ Securities (2016) 380 ITR 612 (Del) and ARN Infrastructure India Ltd. es (2016) 380 ITR 612 (Del) and ARN Infrastructure India Ltd. es (2016) 380 ITR 612 (Del) and ARN Infrastructure India Ltd. Vs ACIT [2017] 394 ITR 569 (Del) a Vs ACIT [2017] 394 ITR 569 (Del) also held that in order to justify the lso held that in order to justify the assumption of Jurisdiction under sectio…

Southern Agrifurane Industries Pvt. Ltd., Chennai vs. ACIT, Central Circle-2(2), Chennai

In the result, both the appeals filed by the Revenue and the

ITA 1237/CHNY/2025[2016-17]Status: DisposedITAT Chennai21 Nov 2025AY 2016-17

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita Nos.1254, 1255, 1258, 1260/Chny/2025 निर्धारणवर्ष/Assessment Years: 2014-15 To 2017-18 The Dcit, Central Circle-2(2), Chennai. (अपीलार्थी/Appellant) V. M/S. Southern Agrifurane Industries Pvt Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita Nos.1233, 1235, 1237, 1238 /Chny/2025 निर्धारणवर्ष/Assessment Years: 2014-15 To 2017-18 M/S. Southern Agrifurane- V. The Dcit, Industries Pvt Ltd Central Circle-2(2), Chennai. Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख /Date Of Pronouncement (प्रत्यर्थी/Respondent) : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025

Section 132Section 143(1)Section 143(2)Section 14ASection 153CSection 250Section 80G

…e reopened, the decision of the Supreme Court in Commissioner of Income Tax-III, Pune Vs. Sinhgad Technical Education Society (Supra) settles the issue and holds this to be an essential requirement. The decision of this Court in CIT-7 Vs RRJ Securities (2016) 380 ITR 612 (Del) and ARN Infrastructure India Ltd. Vs ACIT [2017] 394 ITR 569 (Del) also held that in order to justify the assumption of Jurisdiction under section 153C of the Act the documents settled must be incriminating and must relate to each of the AYs whose assessments are sought to be reopened." 6.4.7 At this juncture, it is appropriate to bring on…

Southern Agrifurane Industries Pvt. Ltd., Chennai vs. ACIT, Central Circle-2(2), Chennai

In the result, both the appeals filed by the Revenue and the

ITA 1235/CHNY/2025[2015-16]Status: DisposedITAT Chennai21 Nov 2025AY 2015-16

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita Nos.1254, 1255, 1258, 1260/Chny/2025 निर्धारणवर्ष/Assessment Years: 2014-15 To 2017-18 The Dcit, Central Circle-2(2), Chennai. (अपीलार्थी/Appellant) V. M/S. Southern Agrifurane Industries Pvt Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita Nos.1233, 1235, 1237, 1238 /Chny/2025 निर्धारणवर्ष/Assessment Years: 2014-15 To 2017-18 M/S. Southern Agrifurane- Industries Pvt Ltd Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-2(2), Chennai. (प्रत्यर्थी/Respondent) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख /Date Of Pronouncement : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025

Section 132Section 143(1)Section 143(2)Section 14ASection 153CSection 250Section 80G

…termination of total income, it would be unjustified in mechanically reopening or assessing all the AYs in question. 28. In this context, we take note of the pertinent observations made by the Hon'ble Delhi High Court in the case of CIT Vs RRJ Securities Ltd (380 ITR 612) wherein the Court held that merely because an article or thing may have been recovered in the course of a search which belongs to `other person' would not mean that the assessments of the 'other person' has to 'necessarily' be reopened under Section 153C unless the material obtained is shown to have a bearing on the determination of the total in…

Chandra Vidya Investment & Finance Pvt. Ltd., New Delhi vs. Deputy Commissioner of Income Tax, Central Circle -28, Delhi, New Delhi

ITA 4023/DEL/2025[2017-18]Status: DisposedITAT Delhi20 Nov 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal, Accountnat Member

Section 153Section 153ASection 153C

…ther held that completed assessments could be interfered with only on the basis of incriminating material unearthed during the course of search. 13. The issue came to be examined in greater detail in CIT v. RRJ Securities Ltd. [2015] 62 taxmann.com 391/[2016] 380 ITR 612/2015 SCC Online Del 13085. Dealing with the imperatives of a correlation between the material discovered in the course of a search and the power to assess or reopen concluded assessments, in RRJ Securities, the Court held:- "33. The record slip belongs to the assessee and, therefore, the action of the Assessing Officer of the searched persons rec…

Chandra Vidya Investment & Finance Pvt. Ltd., New Delhi vs. Deputy Commissioner of Income Tax, Central Circle -28, Delhi, New Delhi

ITA 4022/DEL/2025[2015-16]Status: DisposedITAT Delhi20 Nov 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal, Accountnat Member

Section 153Section 153ASection 153C

…ther held that completed assessments could be interfered with only on the basis of incriminating material unearthed during the course of search. 13. The issue came to be examined in greater detail in CIT v. RRJ Securities Ltd. [2015] 62 taxmann.com 391/[2016] 380 ITR 612/2015 SCC Online Del 13085. Dealing with the imperatives of a correlation between the material discovered in the course of a search and the power to assess or reopen concluded assessments, in RRJ Securities, the Court held:- "33. The record slip belongs to the assessee and, therefore, the action of the Assessing Officer of the searched persons rec…

Chandra Vidya Investment & Finance Pvt. Ltd., New Delhi vs. Deputy Commissioner of Income Tax, Central Circle -28, Delhi, New Delhi

ITA 4021/DEL/2025[2014-15]Status: DisposedITAT Delhi20 Nov 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal, Accountnat Member

Section 153Section 153ASection 153C

…ther held that completed assessments could be interfered with only on the basis of incriminating material unearthed during the course of search. 13. The issue came to be examined in greater detail in CIT v. RRJ Securities Ltd. [2015] 62 taxmann.com 391/[2016] 380 ITR 612/2015 SCC Online Del 13085. Dealing with the imperatives of a correlation between the material discovered in the course of a search and the power to assess or reopen concluded assessments, in RRJ Securities, the Court held:- "33. The record slip belongs to the assessee and, therefore, the action of the Assessing Officer of the searched persons rec…

DCIT Central Circle-28, New Delhi, Delhi vs. Microtek Leasing & Finance Pvt. Ltd., Delhi

ITA 4188/DEL/2025[2012-13]Status: DisposedITAT Delhi10 Nov 2025AY 2012-13

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

For Appellant: Sh. S. S. Nagar, CAFor Respondent: Sh. Jitender Singh, CIT-DR
Section 132(1)Section 143(3)Section 153Section 153C

…the Hon’ble Supreme Court in the 6 M/s Okaya power (P) Ltd. ITA Nos. 4187 & 4188/Del/2025 Microtek Leasing & Finance Pvt. Ltd. case of CIT v. Jasjit Singh [2023] 458 ITR 437 (SC) and the Hon’ble Delhi High Court in the case of CIT v. RRJ Securities Ltd [2016] 380 ITR 612 (Delhi) with regard to the date of reckoning for calculating the assessment years for reopening in the case of a non-searched person/third party, wherein it was observed that as against the date of search, the date on which the AO of the person other than the one searched assumes the possession of the seized assets would be the relevant date for…

DCIT, Central Circle 28, New Delhi, Delhi vs. Microtek Leasing & Finance Pvt. Ltd., Delhi

ITA 4187/DEL/2025[2011-12]Status: DisposedITAT Delhi10 Nov 2025AY 2011-12

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

For Appellant: Sh. S. S. Nagar, CAFor Respondent: Sh. Jitender Singh, CIT-DR
Section 132(1)Section 143(3)Section 153Section 153C

…the Hon’ble Supreme Court in the 6 M/s Okaya power (P) Ltd. ITA Nos. 4187 & 4188/Del/2025 Microtek Leasing & Finance Pvt. Ltd. case of CIT v. Jasjit Singh [2023] 458 ITR 437 (SC) and the Hon’ble Delhi High Court in the case of CIT v. RRJ Securities Ltd [2016] 380 ITR 612 (Delhi) with regard to the date of reckoning for calculating the assessment years for reopening in the case of a non-searched person/third party, wherein it was observed that as against the date of search, the date on which the AO of the person other than the one searched assumes the possession of the seized assets would be the relevant date for…

DCIT, Central Circle -28, New Delhi vs. M/S Okaya Power Private Limited, Delhi

ITA 4186/DEL/2025[2011-12]Status: DisposedITAT Delhi10 Nov 2025AY 2011-12

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

For Appellant: Sh. S. S. Nagar, CAFor Respondent: Sh. Jitender Singh, CIT-DR
Section 132(1)Section 143(3)Section 153Section 153C

…the Hon’ble Supreme Court in the 6 M/s Okaya power (P) Ltd. ITA Nos. 4187 & 4188/Del/2025 Microtek Leasing & Finance Pvt. Ltd. case of CIT v. Jasjit Singh [2023] 458 ITR 437 (SC) and the Hon’ble Delhi High Court in the case of CIT v. RRJ Securities Ltd [2016] 380 ITR 612 (Delhi) with regard to the date of reckoning for calculating the assessment years for reopening in the case of a non-searched person/third party, wherein it was observed that as against the date of search, the date on which the AO of the person other than the one searched assumes the possession of the seized assets would be the relevant date for…