https://www.taxtmi.com/caselaws?id=769580 Delhi HC upheld ITAT's decision that AO lacked jurisdiction under Section 153C for AY 2012-13. Following Ojjus Medicare precedent, the court held that the ten-year block period for reopening assessments under Section 153C must be calculated from the end of the assessment year when satisfaction note was recorded. Since AO recorded satisfaction note on 29.09.2021 (relevant to AY 2022-23), the ten-year period commenced from end of AY 2022-23, making AY 2012-13 fall outside the permissible block period. Revenue's appeal was dismissed. en-us Mon, 21 Apr 2025 00:00:00 +0530 Mon, 28 Apr 2025 08:35:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769580 Delhi HC upheld ITAT's decision that AO lacked jurisdiction under Section 153C for AY 2012-13. Following Ojjus Medicare precedent, the court held that the ten-year block period for reopening assessments under Section 153C must be calculated from the end of the assessment year when satisfaction note was recorded. Since AO recorded satisfaction note on 29.09.2021 (relevant to AY 2022-23), the ten-year period commenced from end of AY 2022-23, making AY 2012-13 fall outside the permissible block period. Revenue's appeal was dismissed. Case-Laws Income Tax Mon, 21 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769580