PCIT v. Ojjus Medicare (P) Ltd.

DCIT CC -15, New Delhi vs. Shiva Consultants Pvt. Ltd., New Delhi

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 4122/Del/2025 : Asstt. Year : 2010-11 Ita No. 4123/Del/2025 : Asstt. Year : 2013-14 Ita No. 4124/Del/2025 : Asstt. Year : 2015-16 Dcit, Vs Shiva Consultants Pvt. Ltd., Central Circle-15, C-360, Lgf, Defence Colony, Amar New Delhi Colony, South Delhi, New Delhi-110024 (Appellant) (Respondent) Pan No. Aaacs8213J Assessee By : Sh. Gaurav Jain & Sh. Tarun Chanana, Advs. Revenue By : Sh. Mahesh Kumar, Cit-Dr Date Of Hearing: 18.12.2025 Date Of Pronouncement: 30.12.2025 Order Per Satbeer Singh Godara: These Revenue’S Three Appeals

…as the case may be. Shiva Consultants Pvt. Ltd. 5. We find no merit in either of the Revenue’s instant twin submissions. This is for the precise reason that hon’ble jurisdictional high court recent landmark decision in PCIT vs. Ojjus Medicare Pvt. Ltd. (2024) 465 ITR 101 (Del.); as followed in the CIT(A) lower appellate discussion, has already settled both these issues in the assessee’s favour and against the department thereby holding that going by section 153A(1) Explanation-I as applicable in an assessment to be framed u/s 153C of the Act, has to count ten years “from the end of the assessment year relevant to…

DCIT CC -15, New Delhi vs. Shiva Consultants Pvt. Ltd., New Delhi

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 4122/Del/2025 : Asstt. Year : 2010-11 Ita No. 4123/Del/2025 : Asstt. Year : 2013-14 Ita No. 4124/Del/2025 : Asstt. Year : 2015-16 Dcit, Vs Shiva Consultants Pvt. Ltd., Central Circle-15, C-360, Lgf, Defence Colony, Amar New Delhi Colony, South Delhi, New Delhi-110024 (Appellant) (Respondent) Pan No. Aaacs8213J Assessee By : Sh. Gaurav Jain & Sh. Tarun Chanana, Advs. Revenue By : Sh. Mahesh Kumar, Cit-Dr Date Of Hearing: 18.12.2025 Date Of Pronouncement: 30.12.2025 Order Per Satbeer Singh Godara: These Revenue’S Three Appeals

…as the case may be. Shiva Consultants Pvt. Ltd. 5. We find no merit in either of the Revenue’s instant twin submissions. This is for the precise reason that hon’ble jurisdictional high court recent landmark decision in PCIT vs. Ojjus Medicare Pvt. Ltd. (2024) 465 ITR 101 (Del.); as followed in the CIT(A) lower appellate discussion, has already settled both these issues in the assessee’s favour and against the department thereby holding that going by section 153A(1) Explanation-I as applicable in an assessment to be framed u/s 153C of the Act, has to count ten years “from the end of the assessment year relevant to…

Nitin Gupta HUF, Delhi vs. Assistant Commissioner of Income Tax, Central Circle -32, Delhi

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 4120/Del/2025 : Asstt. Year : 2014-15 Ita No. 4121/Del/2025 : Asstt. Year : 2015-16 Nitin Gupta Huf, Vs Acit, Bt-54, Shalimar Bagh, Central Circle-32, Delhi-110088 New Delhi-110055 (Appellant) (Respondent) Pan No. Aafhn6836G Assessee By : Sh. Sumit Lalchandani, Adv. Revenue By : Sh. Mahesh Kumar, Cit-Dr Date Of Hearing: 18.12.2025 Date Of Pronouncement: 30.12.2025 Order Per Satbeer Singh Godara: These Assessee’S Twin Appeals

…m the common search conducted on the Alankit group on 18.10.2019. To reiterate, in the instant appeal, the appellant in its submission (supra) has Hon’ble Courts: - Principal Commissioner of Income-tax (Central-1) v. Ojjus Medicare (P.) Ltd reported in [2024] 465 ITR 101 (Delhi); - CIT Vs. Jasjit Singh 458 ITR 437(SC) - Judgments of the Hon’ble Delhi High Court in Writ petitions filed in various cases arising out of the Alankit group search, as listed by the appellant in para 14 of its submission (supra). 10. I have considered the aforesaid submissions made by the appellant. It is seen that in the present appeal,…

Nitin Gupta HUF, Delhi vs. Assistant Commissioner of Income Tax, Central Circle -32, Delhi

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 4120/Del/2025 : Asstt. Year : 2014-15 Ita No. 4121/Del/2025 : Asstt. Year : 2015-16 Nitin Gupta Huf, Vs Acit, Bt-54, Shalimar Bagh, Central Circle-32, Delhi-110088 New Delhi-110055 (Appellant) (Respondent) Pan No. Aafhn6836G Assessee By : Sh. Sumit Lalchandani, Adv. Revenue By : Sh. Mahesh Kumar, Cit-Dr Date Of Hearing: 18.12.2025 Date Of Pronouncement: 30.12.2025 Order Per Satbeer Singh Godara: These Assessee’S Twin Appeals

…m the common search conducted on the Alankit group on 18.10.2019. To reiterate, in the instant appeal, the appellant in its submission (supra) has Hon’ble Courts: - Principal Commissioner of Income-tax (Central-1) v. Ojjus Medicare (P.) Ltd reported in [2024] 465 ITR 101 (Delhi); - CIT Vs. Jasjit Singh 458 ITR 437(SC) - Judgments of the Hon’ble Delhi High Court in Writ petitions filed in various cases arising out of the Alankit group search, as listed by the appellant in para 14 of its submission (supra). 10. I have considered the aforesaid submissions made by the appellant. It is seen that in the present appeal,…

DCIT CC -15, New Delhi vs. Jfc Finance (India) Limited, New Delhi

Appeal is dismissed in above terms

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 4103/Del/2025 : Asstt. Year : 2012-13 Dcit, Vs Jfc Finance (India) Ltd., Central Circle-15, 944/9 & 944/10, Ground Floor, New Delhi Laxmi Complex, Nehru Road, Arjun Nagar, Kotla Mubarakpur, New Delhi-110003 (Appellant) (Respondent) Pan No. Aaacj9731E Assessee By : Sh. Sh. Gaurav Jain, Adv. & Sh. Tarun Chanana, Adv. Revenue By : Sh. Mahesh Kumar, Cit-Dr Date Of Hearing: 18.12.2025 Date Of Pronouncement: 30.12.2025 Order Per Satbeer Singh Godara: This Revenue’S Appeal For Assessment Years 2012-13, Arises Against The Cit(A)-26, New Delhi’S Order Dated 27.02.2025 In Case No. 26/10153/2011-12, In Proceedings U/S 153C R.W.S. 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

…assessment year as on the date of recording of satisfaction. 6. We find no merit in the Revenue’s relevant submissions. This is for the precise reason that hon’ble jurisdictional high court recent landmark decision in PCIT vs. Ojjus Medicare Pvt. Ltd. (2024) 465 ITR 101 (Del.); as followed in the CIT(A) lower appellate discussion, has already settled both these issues in the assessee’s favour and against the department thereby holding that going by section 153A(1) Explanation-I as applicable in an assessment to be framed u/s 153C of the Act, has to count ten years “from the end of the assessment year relevant to…

Assistant Commissioner of Income Tax, Central Circle-25, New Delhi, Delhi vs. Pooja Gupta, Delhi

In the result, the Appeal of the Revenue is dismissed

Bench: Sh. Yogesh Kumar Us & Sh. Naveen Chandra

…he appeal is condoned. 3. In the above appeal, Revenue challenged the order of the ld. CIT(A) dated 13.02.2025 wherein the ld. CIT(A) by relying on the judgment of the Hon’ble jurisdictional High Court in the case of PCIT vs. Ojjus Medicare Pvt. Ltd. (2024) 465 ITR 101 (Del.), allowed the appeal of the assessee. Aggrieved by the order of the ld. CIT(A), Revenue preferred the captioned 2 ITA Nos. 3737 & 3739/Del./2025 Pradeep Kr. & Pooja Gupta appeal. The ld. DR relying on the assessment order, sought for allowing the appeal. 4. It is found that the ld. CIT(A) while setting aside the assessment order observed…

Assistant Commissioner of Income Tax, Central Circle-25, New Delhi, Delhi vs. Pradeep Kumar Gupta (HUF), Delhi

In the result, the Appeal of the Revenue is dismissed

Bench: Sh. Yogesh Kumar Us & Sh. Naveen Chandra

…he appeal is condoned. 3. In the above appeal, Revenue challenged the order of the ld. CIT(A) dated 13.02.2025 wherein the ld. CIT(A) by relying on the judgment of the Hon’ble jurisdictional High Court in the case of PCIT vs. Ojjus Medicare Pvt. Ltd. (2024) 465 ITR 101 (Del.), allowed the appeal of the assessee.Aggrieved by the order of the ld. CIT(A), Revenue preferred the captioned 2 ITA No. 3737 /Del./2025 Pradeep Kumar Gupta appeal. The ld. DR relying on the assessment order, sought for allowing the appeal. 4. It is found that the ld. CIT(A) while setting aside the assessment order observed that the year…

Deputy Commissioner of Income Tax, Delhi vs. Pritam Singh Talwar, Delhi

In the result, the Appeal of the Revenue is dismissed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaldeputy Commissioner Of Vs Pritam Singh Talwar Income Tax, Room No. 343, 3Rd 82, Dayanandvihar, Vikas Marg, Floor, E-2, Ara Centre, Delhi Jhandewalan Extension, Delhi Pan: Abypt9153C

…) dated 20/11/2024 wherein the ld. CIT(A) by relying on the judgments of the Hon'ble Supreme Court in the case of CIT-14 Vs. Jagjit Singh (2023) 458 ITR 437 and the Judgment of jurisdictional High Court in the case of PCIT vs. Ojjus Medicare Pvt. Ltd. (2024) 465 ITR 101 (Del.)allowed the appeal of the assessee. Aggrieved by the order of the ld. CIT(A) dated 20/11/2024, Revenue preferred the captioned 2 DCIT Vs. Pritam Singh Talwar appeal. 3. The ld. DR relying on the assessment order, sought for allowing the appeal. 4. It is found that the ld. CIT(A) while setting aside the assessment order observed that…

Ashok Kumar, Haryana vs. Dy. Commissioner of Income Tax, Delhi

Accordingly all the impugned assessment orders are quashed. Hence, the legal grounds raised by the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shris.Rifaur Rahman

…22-23 2022-23 2023-24 2017-18 to 2022-23 2014-15 to 2023-24 2023-24 2024-25 2018-19 to 2023-24 2015-16 to 2024-25 Further, he submitted that this issue is squarely covered by the judgment of Hon’ble Delhi High Court in PCIT vs. Ojjus Medicare (P) Ltd. (2022) 465 ITR 101 (Del.). Accordingly, he pleaded that the impugned assessments are barred by limitation and the appeals may be allowed.. 7. On the other hand, ld. DR of the Revenue relied on the findings of the AO but could not controvert the aforesaid decisions relied on by the assessee and ld. CIT(A). 8. Considered the rival submissions and material available o…

Ashok Kumar, Haryana vs. Dy. Commissioner of Income Tax, Delhi

Accordingly all the impugned assessment orders are quashed. Hence, the legal grounds raised by the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shris.Rifaur Rahman

…22-23 2022-23 2023-24 2017-18 to 2022-23 2014-15 to 2023-24 2023-24 2024-25 2018-19 to 2023-24 2015-16 to 2024-25 Further, he submitted that this issue is squarely covered by the judgment of Hon’ble Delhi High Court in PCIT vs. Ojjus Medicare (P) Ltd. (2022) 465 ITR 101 (Del.). Accordingly, he pleaded that the impugned assessments are barred by limitation and the appeals may be allowed.. 7. On the other hand, ld. DR of the Revenue relied on the findings of the AO but could not controvert the aforesaid decisions relied on by the assessee and ld. CIT(A). 8. Considered the rival submissions and material available o…

Ashok Kumar, Haryana vs. Dy. Commissioner of Income Tax, Delhi

Accordingly all the impugned assessment orders are quashed. Hence, the legal grounds raised by the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shris.Rifaur Rahman

…22-23 2022-23 2023-24 2017-18 to 2022-23 2014-15 to 2023-24 2023-24 2024-25 2018-19 to 2023-24 2015-16 to 2024-25 Further, he submitted that this issue is squarely covered by the judgment of Hon’ble Delhi High Court in PCIT vs. Ojjus Medicare (P) Ltd. (2022) 465 ITR 101 (Del.). Accordingly, he pleaded that the impugned assessments are barred by limitation and the appeals may be allowed.. 7. On the other hand, ld. DR of the Revenue relied on the findings of the AO but could not controvert the aforesaid decisions relied on by the assessee and ld. CIT(A). 8. Considered the rival submissions and material available o…

Lekhraj, Haryana vs. Dy. Commissioner of Income Tax, Delhi

Accordingly all the impugned assessment orders are quashed. Hence, the legal grounds raised by the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shris.Rifaur Rahman

…22-23 2022-23 2023-24 2017-18 to 2022-23 2014-15 to 2023-24 2023-24 2024-25 2018-19 to 2023-24 2015-16 to 2024-25 Further, he submitted that this issue is squarely covered by the judgment of Hon’ble Delhi High Court in PCIT vs. Ojjus Medicare (P) Ltd. (2022) 465 ITR 101 (Del.). Accordingly, he pleaded that the impugned assessments are barred by limitation and the appeals may be allowed.. 7. On the other hand, ld. DR of the Revenue relied on the findings of the AO but could not controvert the aforesaid decisions relied on by the assessee and ld. CIT(A). 8. Considered the rival submissions and material available o…

JCIT(OSD), Jhandewalan vs. Narendra Aggarwal, Faridabad

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Sudhir Kumar & Shri Manish Agarwaljcit (Osd), Jhandewalan, Vs. Narendra Aggarwal, Delhi H.No. 467, Sector-21-A, Fardidabad, Haryana (Pan: Aagpa1441D) (Appellant) (Respondent) Assessee By : Dr.Rakesh Gupta, Adv., Sh. Somil Agarwal, Adv., Saksham Agarwal, Ca & Deepesh Garg, Adv. Revenue By : Ms. Amisha S. Gupt, Cit Dr Date Of Hearing : 04.11.2025 Date Of Order : 19.12.2025 O R D E R Per Sudhir Kumar, Jm :

…e date of search relevant for the assessee is only AY 2022- 23, hence, AY 2015-16 is unabated and outside the provisions of section 153C of the Act, in view of the decision of the Hon’ble Delhi High Court in the case of Jasjit Singh (supra) and Ojuss Medicare 465 ITR 101 (Del) wherein it has been held that the date of satisfaction note/handing over the books be the date of search. Thus, it is quite essential that ‘satisfaction note’ should be self, contained 20 document about the incriminating material belong to the assessee for the relevant year found in the search leading to assumption of jurisdiction. We obse…

Jagdamba Petroleum India Pvt Ltd, New Delhi vs. DCIT, Central Circle-2, Gurgaon

In the result, the appeals of the assessee are partly allowed

Bench: Shri C.N. Prasad & Shri Manish Agarwal

…the seized materials belonging to the assessee to the AO of the Assessee so as to record satisfaction and initiate proceedings u/s.153C of the Act. 10. We observed that the Hon’ble Jurisdictional High Court in the case of PCIT Vs. Ojjus Medicare Private Ltd. 465 ITR 101 held as under :- “86. In the present batch, List I pertains to writ petitions which have Satisfaction Notes recorded or section 153C notices issued between the period 01 April 2021 to 31 March 2022. Undisputedly, the First Proviso το section 153C, and which has been consistently recognized to also embody the commencement point for reckoning the s…

Jagdamba Petroleum India (P) Ltd, New Delhi vs. DCIT, Central Circle-2, Gurgaon

In the result, the appeals of the assessee are partly allowed

Bench: Shri C.N. Prasad & Shri Manish Agarwal

…the seized materials belonging to the assessee to the AO of the Assessee so as to record satisfaction and initiate proceedings u/s.153C of the Act. 10. We observed that the Hon’ble Jurisdictional High Court in the case of PCIT Vs. Ojjus Medicare Private Ltd. 465 ITR 101 held as under :- “86. In the present batch, List I pertains to writ petitions which have Satisfaction Notes recorded or section 153C notices issued between the period 01 April 2021 to 31 March 2022. Undisputedly, the First Proviso το section 153C, and which has been consistently recognized to also embody the commencement point for reckoning the s…

Blue Breeze Trading LLP, Dlehi vs. DCIT Central Circle -27, Delhi

In the result, the appeal of the assessee is accordingly allowed in above terms for statistical purposes

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

…eals) has failed to appreciate that assessment framed u/s 153C/144 of the Act is barred by limitation and therefore, deserve to be quashed as such in view of the Judgments of Hon'ble Delhi High Court in the case of PCIT vs. Ojjus Medicare (P) Ltd. reported in 465 ITR 101 and, Hon'ble Apex Court in the case of CIT vs. Jasjit Singh reported in 458 ITR 437 the limitation for issuance of notice u/s 153C of the Act under the old regime would be as under: 28.9.2021 Assessment Year FY 2021-22 2022-23(1) AY 2022-23 2021-22(2) 2020-21(3) 2019-20(4) 2018-19(5) 2017-18(6) ……….. ……….. ……….. ……………. 4. That the learned Commis…

Quadra Infratel Synergies Pvt Ltd, Delhi vs. ACIT, Central Circle 4, Delhi, Jhandewalan

In the result, the appeal of the assessee is allowed as indicated above

Bench: Shri C.N. Prasad & Shri M. Balaganesh[Assessment Year: 2014-15] Quadra Infratel Synergies Vs. Acit Pvt. Ltd. B-6/1, Sector-05 Central Circle – 4 Rohini, Delhi Delhi Pan No. Aaecp2894G Appellant Respondent Assessee By Sh. Saksham Singhal, Advocate Ms. Somay Jain, Ca Revenue By Ms. Nimisha Singh, Cit Dr Date Of Hearing 18.09.2025 Date Of Pronouncement 12.12.2025 Order Per C.N. Prasad, Jm, This Appeal Filed By The Assessee Is Preferred Against The Order Of The Commissioner Of Income Tax (Appeals), Delhi - 110023 [Herein After Referred As “Cit(A)”] Dated 29.06.2024 For A.Y. 2014-15. 2. The Assessee Has Raised Following Grounds On Validity Of Assessment Proceedings :- “1. That On The Facts & Circumstances Of The Case & In Law, The Commissioner Of Income Tax (Appeals) ['Cit(A)'] Erred In Not Completely Allowing The Appeal Filed By The Appellant Against The Order Dated 29.03.2023 Passed By The Assessing Officer Under Section 1530 R.W.S 143(3) Of The Income Tax Act, 1961 ('The Act").

…el for the assessee submits that in view of the decision of the Hon’ble Supreme Court in the case of CIT Vs. Jasjit Singh reported in 155 taxmann.com 154 and the decision of the Hon’ble Delhi High Court in the case of PCIT Vs. Ojjus Medicare Ltd., reported in 465 ITR 101, the year of handing over documents to the AO of non-searched person shall be considered as year of search for the purpose of section 153C and in which case block period of six assessment years shall be from 2022-23 to 2016-17, since the date of handing over of documents by the AO of the searched person to the AO of the assessee who is the non se…

Assistant Commissioner of Income Tax, Central Circle-25, New Delhi, Delhi vs. Pankaj Gupta(HUF), Delhi

In the result, the Appeal of the Revenue is dismissed

Bench: Sh. Yogesh Kumar Us & Sh. Naveen Chandra

…he appeal is condoned. 3. In the above appeal, Revenue challenged the order of the ld. CIT(A) dated 13.02.2025 wherein the ld. CIT(A) by relying on the judgment of the Hon’ble jurisdictional High Court in the case of PCIT vs. Ojjus Medicare Pvt. Ltd. (2024) 465 ITR 101 (Del.), allowed the appeal of the assessee. Aggrieved by the order of the ld. CIT(A), Revenue preferred the captioned 2 ITA No. 3745/Del./2025 PankajGupta(HUF) appeal. The ld. DR relying on the assessment order, sought for allowing the appeal. 4. It is found that the ld. CIT(A) while setting aside the assessment order observed that the year un…

Assistant Commissioner of Income Tax, Central Circle-25, New Delhi, Delhi vs. Pankaj Gupta HUF, Delhi

In the result, the Appealof the Revenue is dismissed

Bench: Sh. Yogesh Kumar Us & Sh. Naveen Chandra

…he appeal is condoned. 3. In the above appeal, Revenue challenged the order of the ld. CIT(A) dated 13.02.2025 wherein the ld. CIT(A) by relying on the judgment of the Hon’ble jurisdictional High Court in the case of PCIT vs. Ojjus Medicare Pvt. Ltd. (2024) 465 ITR 101 (Del.), allowed the appeal of the assessee.Aggrieved by the order of the ld. CIT(A), Revenue preferred the captioned 2 ITA No. 3744/Del./2025 PankajGupta appeal. The ld. DR relying on the assessment order, sought for allowing the appeal. 4. It is found that the ld. CIT(A) while setting aside the assessment order observed that the year under co…