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“time barred assessment”

Assessment ProceduresSection 153Section 153144 judgments

RAJESH GANDHI,NEW DELHI vs. SANGHPRIYA SINGH, DCIT, CENTRAL CIRCLE-28, NEW DELHI, NEW DELHI

The appeals are dismissed

ITA 664/DEL/2025[2021-22]Status: DisposedITAT Delhi29 Jan 2026AY 2021-22

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh

Section 132Section 139(1)Section 153Section 153CSection 68

Before us, the ld. counsel for the assessee vehemently stated that assessment made for A.Ys 2011-12 and 2012-13 is a time barred assessment. The ld. counsel for the assessee pointed out that in this case, search and seizure u/s 132 of the Act was undertaken on Alankit Group

RAJESH GANDHI,NEW DELHI vs. SANGHPRIYA SINGH, DCIT, CENTRAL CIRCLE-28, NEW DELHI, NEW DELHI

The appeals are dismissed

ITA 663/DEL/2025[2020-21]Status: DisposedITAT Delhi29 Jan 2026AY 2020-21

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh

Section 132Section 139(1)Section 153Section 153CSection 68

Before us, the ld. counsel for the assessee vehemently stated that assessment made for A.Ys 2011-12 and 2012-13 is a time barred assessment. The ld. counsel for the assessee pointed out that in this case, search and seizure u/s 132 of the Act was undertaken on Alankit Group

RAJESH GANDHI,NEW DELHI vs. SANGHPRIYA SINGH, DCIT, CENTRAL CIRCLE-28, NEW DELHI, NEW DELHI

Appeals are dismissed

ITA 662/DEL/2025[2019-20]Status: DisposedITAT Delhi29 Jan 2026AY 2019-20
Section 132Section 139(1)Section 153Section 153CSection 68

nBefore us, the ld. counsel for the assessee vehemently stated that assessment\nmade for A.Ys 2011-12 and 2012-13 is a time barred assessment. The ld. counsel for\nthe assessee pointed out that in this case, search and seizure u/s 132 of the Act was\nundertaken on Alankit Group

RAJESH GANDHI,NEW DELHI vs. SANGHPRIYA SINGH, DCIT CENTRAL CIRCLE-28, NEW DELHI, NEW DELHI

The appeals are dismissed

ITA 661/DEL/2025[2012-13]Status: DisposedITAT Delhi29 Jan 2026AY 2012-13

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh

Section 132Section 139(1)Section 153Section 153CSection 68

Before us, the ld. counsel for the assessee vehemently stated that assessment made for A.Ys 2011-12 and 2012-13 is a time barred assessment. The ld. counsel for the assessee pointed out that in this case, search and seizure u/s 132 of the Act was undertaken on Alankit Group

RAMESH GANDHI,NEW DELHI vs. SANGHPRIYA SINGH, DCIT, CENTRAL CIRCLE-28, NEW DELHI, NEW DELHI

The appeals are dismissed

ITA 657/DEL/2025[2012-13]Status: DisposedITAT Delhi29 Jan 2026AY 2012-13

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh

Section 132Section 139(1)Section 153Section 153CSection 68

Before us, the ld. counsel for the assessee vehemently stated that assessment made for A.Ys 2011-12 and 2012-13 is a time barred assessment. The ld. counsel for the assessee pointed out that in this case, search and seizure u/s 132 of the Act was undertaken on Alankit Group

EXPRESS FREIGHT RAILWAY CONSORTIUM,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 28(1), NEW DELHI

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

ITA 3120/DEL/2025[2021-22]Status: DisposedITAT Delhi28 Jan 2026AY 2021-22

Bench: Shri C.N. Prasad & Shri M. Balaganeshassessment Year 2021-22 Express Freight Railway Vs. Dcit Consortium Circle – 28 (1) Room No.22, C4 District New Delhi Centre C/O Ircon International Limited Saket South Delhi, New Delhi Pan No. Aabae0055F Appellant Respondent Appellant Sh. Parshant Merharchandani, Advocate Ms. Kanika Jain, Advocate Respondent Sh. Dharm Veer Singh, Cit (Dr)

Section 144Section 144CSection 144C(13)Section 153Section 153BSection 234ASection 270A

Applying principles laid down by Hon'ble Supreme Court, only relevant fact necessary for deciding Ground No. 4 in present appeal relating to time barred assessment, is time of uploading by DRP of DRP order onto ITBA portal. Intimation letter to DRP order unambiguously shows 27th April 2022 as date

SRI SAT SAHIB HOUSING AND INFRASTRUCTURE DEVELOPMENT COMPANY,GURGAON vs. DCIT/ACIT CC-31, NEW DELHI, DELHI

In the result, both the captioned appeals of the Revenue in ITA Nos

ITA 3115/DEL/2025[2010-11]Status: DisposedITAT Delhi28 Jan 2026AY 2010-11

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh

Section 132Section 153C

counsel for the assessee submitted stated that assessment made for A. Ys 2008-09, 2009-10 and 2010-11 are time barred assessment. The ld. ITA No.- 3113 to 3115/Del/2025 counsel for the assessee pointed out that in this case, search and seizure u/s 132 of the Act was conducted ... Before us, the ld. counsel for the assessee vehemently stated that assessment made for A.Ys 2011-12 and 2012-13 is a time barred assessment. The ld. counsel for 5 ITA No.- 3113 to 3115/Del/2025 the assessee pointed out that in this case, search and seizure

SRI SAT SAHIB HOUSING AND INFRASTRUCTURE DEVELOPMENT COMPANY,GURGAON vs. DCIT/ACIT CC-31, NEW DELHI, DELHI

In the result, both the captioned appeals of the Revenue in ITA Nos

ITA 3114/DEL/2025[2009-10]Status: DisposedITAT Delhi28 Jan 2026AY 2009-10

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh

Section 132Section 153C

counsel for the assessee submitted stated that assessment made for A. Ys 2008-09, 2009-10 and 2010-11 are time barred assessment. The ld. ITA No.- 3113 to 3115/Del/2025 counsel for the assessee pointed out that in this case, search and seizure u/s 132 of the Act was conducted ... Before us, the ld. counsel for the assessee vehemently stated that assessment made for A.Ys 2011-12 and 2012-13 is a time barred assessment. The ld. counsel for 5 ITA No.- 3113 to 3115/Del/2025 the assessee pointed out that in this case, search and seizure

SRI SAT SAHIB HOUSING AND INFRASTRUCTURE DEVELOPMENT COMPANY,GURGAON vs. DCIT/ ACIT CC-31 NEW DELHI, NEW DELHI

In the result, both the captioned appeals of the Revenue in ITA Nos

ITA 3113/DEL/2025[2008-09]Status: DisposedITAT Delhi28 Jan 2026AY 2008-09

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh

Section 132Section 153C

counsel for the assessee submitted stated that assessment made for A. Ys 2008-09, 2009-10 and 2010-11 are time barred assessment. The ld. ITA No.- 3113 to 3115/Del/2025 counsel for the assessee pointed out that in this case, search and seizure u/s 132 of the Act was conducted ... Before us, the ld. counsel for the assessee vehemently stated that assessment made for A.Ys 2011-12 and 2012-13 is a time barred assessment. The ld. counsel for 5 ITA No.- 3113 to 3115/Del/2025 the assessee pointed out that in this case, search and seizure

DCIT,CENTRAL CIRCLE-1, GUWAHATI vs. SATISH JALAN, SHILLONG

Appeal of the Revenue is allowed for statistical purposes

ITA 62/GTY/2025[2017-18]Status: DisposedITAT Guwahati17 Nov 2025AY 2017-18

Bench: Hon'Ble Itat. 3. There Are Currently More Than 300 Time Barred Assessment & 200 Penalty Cases Are Pending In This Office. Due To Shortage Of Manpower It Was Delayed In The Filing Of Appeal Before Hon'Ble Itat.

Section 131Section 250Section 68

related error occurred in ITBA which further delayed the filling of appeal before Hon'ble ITAT. 3. There are currently more than 300 time barred assessment and 200 penalty cases are pending in this office. Due to shortage of manpower it was delayed in the filing of appeal before

SYED IRFAN GULAB JAN PASHA,BANGALORE vs. INCOME TAX OFFICER, WARD-1(2)(3), BANGALORE

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 1095/BANG/2025[2012-13]Status: DisposedITAT Bangalore22 Oct 2025AY 2012-13

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.

For Appellant: Shri H. Guruswamy, ITPFor Respondent: Shri Thamba Mahendra, JCIT-DR
Section 148Section 250Section 271(1)(c)Section 69ASection 7

without appreciating the facts Rs. 4,48,539 /- and circumstances of the Case that the Penalty so levied was based on the time barred Assessment Order. The Ld. CIT(A) NFAC has erred in confirming the Penalty of Rs. 4,48,539 /- imposed by the AO merely based

SYED IRFAN GULAB JAN PASHA ,BANGALORE vs. INCOME TAX OFFICER, WARD-1(2)(3), BANGALORE

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 1094/BANG/2025[2012-13]Status: DisposedITAT Bangalore22 Oct 2025AY 2012-13

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.

For Appellant: Shri H. Guruswamy, ITPFor Respondent: Shri Thamba Mahendra, JCIT-DR
Section 148Section 250Section 271(1)(c)Section 69ASection 7

without appreciating the facts Rs. 4,48,539 /- and circumstances of the Case that the Penalty so levied was based on the time barred Assessment Order. The Ld. CIT(A) NFAC has erred in confirming the Penalty of Rs. 4,48,539 /- imposed by the AO merely based

BMW INDIA PVT LTD,HARYANA vs. ACIT CIRCLE1(1), GURGAON

In the result, Appeal of the Assessee is allowed

ITA 2024/DEL/2022[2011-12]Status: DisposedITAT Delhi12 Sept 2025AY 2011-12

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.Bmw India Pvt. Ltd. Vs Assistant Commissioner 2Nd Floor, Oberoi Centre Of Income Tax, Circle (1), Building No. 11, Dlf Cyber Hsiidc Building, Vanijya City Dlf Phase, Gurgaon, Nikunj Udhyog Vihar, Haryuana, 122001 Phase-5, Gurgaon, Pan: Aabcb7140C Haryana Appellant Respondent Assessee By Sh. Himanshu S. Sinha-Adv, Ms. Kanika Jain, Adv& Sh. Prashant Meharchandani, Adv Revenue By Sh. S. K. Jadhav, Cit- Dr Date Of Hearing 06/08/2025 Date Of Pronouncement 12/09/2025 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Challenging The Final Assessment Order Passed By Assistant Commissioner Of Income Tax, Circle -1(1)-Gurgaon, Dated 28/06/2022 U/S254R.W. Section 143(3)/144C Of The Income Tax Act, 1961 ('Act' For Short).

Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 153Section 254Section 254rSection 92C

Applying principles laid down by Hon'ble Supreme Court, only relevant fact necessary for deciding Ground No. 4 in present appeal relating to time barred assessment, is time of uploading by DRP of DRP order onto ITBA portal. Intimation letter to DRP order unambiguously shows 27th April 2022 as date

SHAH RAKESH BHIKHABHAI (HUF),AHMEDABAD vs. THE PCIT, AHMEDABAD-1, AHMEDABAD

In the result, the appeal filed by the assessee stands dismissed

ITA 415/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad18 Jul 2025AY 2018-19

Bench: Shri T.R Senthil Kumar & Shri Narendra Prasad Sinha

For Appellant: Shri Vivek Chavda, ARFor Respondent: Shri A P Singh, CIT. DR
Section 142(1)Section 143(3)Section 80G

provisions of section 263. The revenue cannot be granted license to reassess the assessee again and again upon the same issue in a time barred assessment which is already concluded by the assessing officer after applying his mind and conducting sufficient 150 enquiry. 2.6 Lastly, without prejudice to the above

VAKA GHANTA NAGESWARARAO,GUNTUR vs. INCOME TAX OFFICER, WARD - 1, TENALI

In the result, appeal filed by the assessee is allowed

ITA 251/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam10 Jul 2025AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.251/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2015-16) Vs. Income Tax Officer-Ward – 1 Vaka Ghanta Nageswararao 4-82-A, Gullapalli Tenali -522201 Goudapalem, Cherukapalli Mandal Andhra Pradesh Guntur – 522309 Andhra Pradesh [Pan:Afjpn4315H] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Malladi Muralidhar, Ca करदाता का प्रतततितित्व/ Assessee Represented By राजस्व का प्रतततितित्व/ Department Represented By : Dr.Aparna Villuri, Sr. Ar

Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 149(1)(b)Section 250(6)Section 69ASection 80C

ITAT-Kol 8.2 The validity can be challenged at any stage – SC in Kiran singh vs. Chaman Paswan (AIR 1954 SC 340) 9. Time barred assessment order: The Ld AO was not justified in passing the assessment order u/s 147 rws 144 on 08.12.2023, with respect to notices u/s 148A

ROLLS-ROYCE INDIA PRIVATE LIMITED ,DELHI vs. DCIT TP 3(2)(1), DELHI

The appeal is allowed as indicated above

ITA 252/DEL/2022[2017-18]Status: DisposedITAT Delhi04 Jul 2025AY 2017-18

Bench: Shri Ramit Kochar & Shri Sudhir Pareek

For Appellant: Shri Nikhil Tiwari, AdvFor Respondent: Shri S.K. Jadhav, CIT-DR
Section 143(3)Section 144C(5)

Applying principles laid down by Hon'ble Supreme Court, only relevant fact necessary for deciding Ground No. 4 in present appeal relating to time barred assessment, is time of uploading by DRP of DRP order onto ITBA portal. Intimation letter to DRP order unambiguously shows 27th April 2022 as date

JONES LANG LASALLE PROPERTY CONSULTANTS (INDIA) PRIVATE LIMITED,DELHI, INDIA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 13(1), DELHI, INDIA

In the result, the appeal of the assessee is allowed and the Stay

ITA 3964/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Jun 2025AY 2020-21

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2020-21 & Stay Application No.61/Del/2025 ( In Ita No. 3964/Del/2024 ) Assessment Year: 2020-21

For Appellant: S/Shri Nageshwar Rao and ParthFor Respondent: ShriDharam Veer Singh, CIT (DR)
Section 142(1)Section 143(2)Section 143(3)Section 144BSection 144CSection 144C(12)Section 144C(13)Section 144C(5)Section 41Section 92

Applying principles laid down by Hon'ble Supreme Court, only relevant fact necessary for deciding Ground No. 3 in present appeal relating to time barred assessment, is time of uploading by DRP of DRP order onto ITBA portal. Intimation letter to DRP order unambiguously shows 31.05.2024 as date of uploading

JCIT(OSD), DELHI vs. URJAA METALICS PVT LTD EARLIER KNOWN AS ACCIL AUTO STEELS (P) LTD, DELHI

In the result, all captioned appeals/Cross-Objections etc

ITA 347/DEL/2024[2015-16]Status: DisposedITAT Delhi28 May 2025AY 2015-16
For Respondent: \nMs. Monika Singh, CIT, DR
Section 153Section 153(3)Section 153A

result, all captioned appeals/Cross-Objections etc. of the assessee are\nallowed whereas all the captioned appeals/Cross-objections etc. of the Revenue arising\nfrom time barred assessment orders are dismissed.\n5. Thus, having regard to this entire aspect of the matter and\nparticularly considering the order passed by the Coordinate Bench

JCIT(OSD), DELHI vs. URJAA METALICS PVT LTD EARLIER KNOWN AS ACCIL AUTO STEELS (P) LTD, NEW DELHI

In the result, all captioned appeals/Cross-Objections etc

ITA 346/DEL/2024[2016-17]Status: DisposedITAT Delhi28 May 2025AY 2016-17
Section 153Section 153(3)Section 153A

result, all captioned appeals/Cross-Objections etc. of the assessee are\nallowed whereas all the captioned appeals/Cross-objections etc. of the Revenue arising\nfrom time barred assessment orders are dismissed.\n\n5. Thus, having regard to this entire aspect of the matter and\nparticularly considering the order passed by the Coordinate Bench

URJAA METALICS PVT. LTD. (EARLIER KNOWN AS ACCIL AUTO STEELS PVT. LTD.),NEW DELHI vs. ACIT CENTRAL CIRCLE-29, NEW DELHI

The appeals of the assessee are allowed and appeals of the Revenue\nare dismissed

ITA 3920/DEL/2023[2016-17]Status: DisposedITAT Delhi28 May 2025AY 2016-17
Section 153Section 153(3)Section 153A

result, all captioned appeals/Cross-Objections etc. of the assessee are\nallowed whereas all the captioned appeals/Cross-objections etc. of the Revenue arising\nfrom time barred assessment orders are dismissed.\n5. Thus, having regard to this entire aspect of the matter and\nparticularly considering the order passed by the Coordinate Bench

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