“block period”

G S Automobiles Private Limited, Delhi vs. DCIT, Central Circle-6, Delhi

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

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmang.S. Automobiles Private Limited, Vs. Dcit, Central Circle 6, B – 26, Okhla Industrial Area, Phase Ii, Delhi. Delhi – 110 020. (Pan : Aadcg1150B) (Appellant) (Respondent) Assessee By : Shri Neeraj Mangla, Ca Revenue By : Shri Jitender Singh, Cit Dr Date Of Hearing : 19.11.2025 Date Of Order : 30.12.2025 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals), Delhi – 24 [“Ld. Cit(A)”, For Short] Dated 19.06.2025 For The Assessment Year 2015-16 Raising Following Grounds Of Appeal :- “1. That The Orders Passed By Ld. Ao U/S 153C Of The Act As Well As Appellate Order Passed By Ld. Cit(A) Are Bad In Law & Are Passed In Contravention Of Prevailing Law As Well As Facts Of The Case, Therefore Liable To Be Annulled. 2. That Assumption Of Jurisdiction Of Ld. Ao In Consequence Of Order Passed By Ld. Pcit U/S 127(3) Of The Act Of The Act Is Illegal & Not Tenable Under The Law Because Of Said Order Being Mechanical & Being Passed

issue notices in respect of AYs' prior to or those falling after those two AYs' and which may otherwise fall within the maximum block period of ten years merely because the statute empowers the AO to do so. Unless the material gathered and recovered is found to have relevancy

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

which the block of six AYs' or the "relevant assessment year" would have to be calculated. The contention of the respondents that the said block periods would, have to be reckoned with reference to the date of search thus can neither be countenanced nor possibly accepted. That submission is clearly ... petitioners have correctly identified the aforesaid distinction as being crucial and determinative for the purposes of reckoning the six and the ten AY block period. In the aforesaid judgment, the Hon’ble Court also held as below: “..B. Both Sections 153A and 153C embody non-obstante clauses

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

which the block of six AYs' or the "relevant assessment year" would have to be calculated. The contention of the respondents that the said block periods would, have to be reckoned with reference to the date of search thus can neither be countenanced nor possibly accepted. That submission is clearly ... petitioners have correctly identified the aforesaid distinction as being crucial and determinative for the purposes of reckoning the six and the ten AY block period. In the aforesaid judgment, the Hon’ble Court also held as below: “..B. Both Sections 153A and 153C embody non-obstante clauses

Prashant Soni, New Delhi vs. DCIT, Central Circle-7, Delhi

In the result, the appeal of the assessee is allowed

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanprashant Soni, Vs. Dcit, Central Circle 7, M-50, First Floor, Delhi. Guru Harkishan Nagar, Sunder Vihar, New Delhi – 110 087. (Pan : Basps5961H) (Appellant) (Respondent) Assessee By : Shri Ankit Kumar, Advocate Revenue By : Shri Jitender Singh, Cit Dr Date Of Hearing : 17.11.2025 Date Of Order : 30.12.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)-24, New Delhi [Hereinafter Referred To As ‘Ld. Cit (A)] Dated 30.08.2022 For Assessment Year 2015-16. 2. At The Outset, Ld. Ar Of The Assessee Raised Legal Issue Relating To Assumption Of Jurisdiction Under Section 153C Of The Income-Tax Act, 1961 (For Short ‘The Act’) By Raising Ground Nos.1 & 2 Which Read As Under :- “1. On The Facts & Circumstances Of The Case, The Order Passed By The Ld. Ao & Impugned Order Passed By The Cit (A) Is Bad Both In The Eye Of Law & On Facts.

having a bearing on the determination of income. However, the AO, should have recorded a separate satisfaction for each year falling in the block period of six years and for which he has to issue separate notice u/s 153C for each year falling in the block period of six years ... after obtaining separate approval u/s. 153D for each year falling in the block period of six years. But in the instant case, the AO has recorded a consolidated satisfaction note for A.Y. 2013-14 to A.Y. 2019-20. Thus, the assessment proceeding-initiated u/s 153Cin this case

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

while setting aside the assessment order observed that the year under consideration is not covered within the six assessment years block period for the purpose of making assessment as per section 153C of the Act and by following the ratio laid down by the Hon'ble Supreme Court

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

observed that thus Assessment Year 2012-13, impugned assessment year in the present appeal before us, clearly falls outside the prescribed block period and no proceedings for this year can be sustained in law. We observed that the assessment year 2012-13 under consideration clearly falls outside the scope

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

observed that thus Assessment Year 2012-13, impugned assessment year in the present appeal before us, clearly falls outside the prescribed block period and no proceedings for this year can be sustained in law. We observed that the assessment year 2012-13 under consideration clearly falls outside the scope

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

observed that thus Assessment Year 2012-13, impugned assessment year in the present appeal before us, clearly falls outside the prescribed block period and no proceedings for this year can be sustained in law. We observed that the assessment year 2012-13 under consideration clearly falls outside the scope

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

observed that thus Assessment Year 2012-13, impugned assessment year in the present appeal before us, clearly falls outside the prescribed block period and no proceedings for this year can be sustained in law. We observed that the assessment year 2012-13 under consideration clearly falls outside the scope

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 :

year and issued notice u/s. 153C of the Act dated 09.10.2022. Therefore, the impugned year is beyond 6 years and is thus outside of block period, and hence, the AY 2015-16 is outside the provisions of section 153C of the Act. Also it is noted that as per satisfaction ... year and issued notice u/s. 153C of the Act dated 09.10.2022. Therefore, the impugned year is beyond 6 years and is thus outside of block period, and hence, the AY 2015-16 is outside the provisions of section 153C of the Act. Also it is noted that as per satisfaction

DCIT, Central Circle-28, New Delhi vs. Anisha Gupta, New Delhi

In the result, all the six appeals of the revenue are hereby dismissed

Bench: The Tribunal.

Whether on the facts and under the circumstances of the case and in law, the Ld. CIT(A) was justified in holding that block periods for assessment under section 153C(1) of the Income-tax Act, 1961, have to be calculated six years prior to the AY in which satisfaction

DCIT, Central Circle-28 New Delhi, New Delhi vs. Anisha Gupta, New Delhi

In the result, all the six appeals of the revenue are hereby dismissed

Bench: The Tribunal.

Whether on the facts and under the circumstances of the case and in law, the Ld. CIT(A) was justified in holding that block periods for assessment under section 153C(1) of the Income-tax Act, 1961, have to be calculated six years prior to the AY in which satisfaction

DCIT, Central Circle-28 New Delhi, New Delhi vs. Ankur Gupta HUF, New Delhi

In the result, all the six appeals of the revenue are hereby dismissed

Bench: The Tribunal.

Whether on the facts and under the circumstances of the case and in law, the Ld. CIT(A) was justified in holding that block periods for assessment under section 153C(1) of the Income-tax Act, 1961, have to be calculated six years prior to the AY in which satisfaction

DCIT, Central Circle 28, New Delhi vs. Ankur Gupta HUF, New Delhi

In the result, all the six appeals of the revenue are hereby dismissed

Bench: The Tribunal.

Whether on the facts and under the circumstances of the case and in law, the Ld. CIT(A) was justified in holding that block periods for assessment under section 153C(1) of the Income-tax Act, 1961, have to be calculated six years prior to the AY in which satisfaction