2025 (7) TMI 110

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....eerthi Narayanan, JCIT ORDER PER ABY T. VARKEY, JM: This is an appeal preferred by the assessee against the order of the Learned Commissioner of Income Tax (Appeals)/NFAC, (hereinafter referred to as "the Ld.CIT(A)"), Delhi, dated 18.06.2024 for the Assessment Year (hereinafter referred to as "AY") 2011-12. 2. At the outset, the Ld. Counsel for the assessee submitted that there is a de....

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....ch reads as under: 4. On the facts and circumstances of the case, the First Appellate authority not justified in sustaining the order of the lower authorities when the legal position is that the order passed by the AO dated 04.12.2019 is barred by limitations in terms of section 153(2) of the Act. For the notice issued u/s. 148 dated 24.03.2018, the reassessment should have been completed on or....

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....der: 153. Time limit for completion of assessment, reassessment and re-computation. ...... ..... ..... ...... ..... (2) No order of assessment, reassessment or re-computation shall be made under section 147 after the expiry of nine months from the end of the financial year in which the notice under section 148 was served: 7. From a ....

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.... the AO categorically recorded in the assessment order that "............... notice u/s. 148 of the Act was issued to the assessee on 24.03.2018 after recording reasons and after obtaining necessary approval from the Ld.PCIT, Salem, and the same was duly served on the assessee". In the light of the factual assertion as made by AO of issue and serving of notice in March 2018, we are of the view tha....