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“Section 3(1)(a)”

Section References (mined)Section 3Section 3(1)(a)4 judgments

SANDEEP KUMAR AGARWAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE-7, NEW DELHI

Appeal is dismissed

ITA 300/DEL/2023[2016-17]Status: DisposedITAT Delhi07 Jul 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2016-17 Vs. Dcit, Sh. Sandeep Kumar Agarwal, 1135, Chatta Madan Gopal, Central Circle-7, Maliwara, Chandni Chowk, New Delhi New Delhi Pan: Agtpa3365R (Appellant) (Respondent) Assessee By Sh. Manju Goel, Ca Department By Sh. Mahesh Kumar, Cit(Dr) Date Of Hearing 07.07.2025 Date Of Pronouncement 07.07.2025 Order Per Satbeer Singh Godara, Jm This Assessee’S Appeal For Assessment Year 2016-17, Arises Against The Commissioner Of Income Tax (Appeals)-24 [In Short, The “Cit(A)”], Delhi’S Order Dated 14.12.2022 Passed In Case No. Cit(A), Delhi-24/10751/2015-16, Involving Proceedings Under Section 153C R.W.S. 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). Heard Both The Parties. Case File Perused. 2. This Assessee’S Appeal Raises The Following Substantive Grounds:

Section 143(2)Section 153ASection 153C

Certain Provisions) Act 2020, ("TOLA"), which included the time period during the period from 20th March, 2020 to 31st December, 2020 as per section 3(1)(a) thereof. This being the clinching factual position, we hereby conclude that the learned Assessing Officer’s section 153C notice issued to the assessee

THE ACIT,CENTRAL CIRCLE-1, BHOPAL, BHOPAL vs. DB POWER LTD, BHOPAL

Appeal is dismissed

ITA 73/IND/2023[2015-16]Status: DisposedITAT Indore24 Jan 2024AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Db Power Limited, Acit, Central Circle-1, बनाम/ Office Block, 1A, Bhopal Vs. Db City Park, 5Th Floor, Corporate Block, Opp. M.P. Nagar Zone-1, Arera Hills, Bhopal (Pan:Aaccd5475F) (Assessee/Appellant) (Revenue/Respondent) Acit, Central Circle-1, M/S Db Power Limited, बनाम/ Bhopal Office Block, 1A, Vs. Db City Park, 5Th Floor, Corporate Block, Opp. M.P. Nagar Zone-1, Arera Hills, Bhopal (Pan:Aaccd5475F) (Revenue/Appellant) (Assessee/Respondent)

Section 139(1)Section 143(1)Section 143(2)Section 147Section 148Section 151Section 56(2)(viib)Section 69C

therefore the time-limit to issue notice would expire on 31.03.2022. Being so, the TOLA is not applicable because section 3(1)(a) of TOLA, re-produced above, clearly prescribes its applicability to cases where the time-limit for issuing notice was to expire during 20.03.2020 to 29.06.2020 or such ... other date after 29.06.2020 as the Central Govt. may notify. Since the Central Govt. ultimately notified 31.03.2021, the section 3(1)(a) was applicable only for the situations where the time-limit would expire upto cut-off date of 31.03.2021. In assessee’s case, the time limit to issue notice

DB POWER LTD,BHOPAL vs. THE ACIT,CENTRAL CIRCLE-1, BHOPAL, BHOPAL

Appeal is dismissed

ITA 68/IND/2023[2015-16]Status: DisposedITAT Indore24 Jan 2024AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Db Power Limited, Acit, Central Circle-1, बनाम/ Office Block, 1A, Bhopal Vs. Db City Park, 5Th Floor, Corporate Block, Opp. M.P. Nagar Zone-1, Arera Hills, Bhopal (Pan:Aaccd5475F) (Assessee/Appellant) (Revenue/Respondent) Acit, Central Circle-1, M/S Db Power Limited, बनाम/ Bhopal Office Block, 1A, Vs. Db City Park, 5Th Floor, Corporate Block, Opp. M.P. Nagar Zone-1, Arera Hills, Bhopal (Pan:Aaccd5475F) (Revenue/Appellant) (Assessee/Respondent)

Section 139(1)Section 143(1)Section 143(2)Section 147Section 148Section 151Section 56(2)(viib)Section 69C

therefore the time-limit to issue notice would expire on 31.03.2022. Being so, the TOLA is not applicable because section 3(1)(a) of TOLA, re-produced above, clearly prescribes its applicability to cases where the time-limit for issuing notice was to expire during 20.03.2020 to 29.06.2020 or such ... other date after 29.06.2020 as the Central Govt. may notify. Since the Central Govt. ultimately notified 31.03.2021, the section 3(1)(a) was applicable only for the situations where the time-limit would expire upto cut-off date of 31.03.2021. In assessee’s case, the time limit to issue notice

SULTAN ENTERPRISES PVT. LTD,,SUNDARPADA, BHUBANESWAR vs. PR. CIT-1, BHUBANESWAR

In the result appeal of the assessee in ITA No

ITA 29/CTK/2023[2015-16]Status: HeardITAT Cuttack26 May 2023AY 2015-16

Bench: Before S/Shri George Mathan, Judicial & And Ramit Kocharassessment Year : 2015-16 Sultan Enterprises Pvt Ltd., Sultan Enterprises Pvt Ltd., Vs. Pr. Cit, Bhubaneswar Pr. Cit, Bhubaneswar-1 At:Plot No.161, Azad Nagar, At:Plot No.161, Azad Nagar, Sundarpada, Bhubaneswar. Sundarpada, Bhubaneswar. Pan/Gir No. Pan/Gir No.Aascs 1016 R (Appellant (Appellant) .. ( Respondent Respondent)

For Appellant: Shri Sidharth Ray, Sr. AdvocateFor Respondent: Shri Abani Kanta Nayak, CIT DR
Section 143(3)Section 263

Short ‘TOLA, 2020’) which received the assent of the President of India on 29.09.2020. The ld. Sr. Advocate drew our attention to Section 3(1) of the TOLA, 2020 and P a g e 9 | 20 Assessment Year : 2015-16 submitted that where, any time limit has been specified ... that Income-tax Act, 1961 is a specified Act in Section 2 of TOLA, 2020. Our attention was drawn to Section 3(1)(a) of the TOLA Act, 2020. It was submitted by ld. CIT DR that TOLA, 2020 is a substantive act which extended the limitation, inter-alia