2025 (12) TMI 1760

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....ECG2030K) for AY 2014-15 was received in the office of Pr. CIT, Central-3 on 08.04.2025 and authorization for filing of appeal before the Hon'ble ITAT was received in this office on 11.07.2025 (copy enclosed). The date of limitation for filing of appeal before Hon'ble ITAT was 06.06.2025. 3. In this regard, it is submitted that the undersigned was busy in time barring scrutiny, judicial, audit and other time barring matters. The under mentioned charge has heavy workload due to lots of pendency of time barring assessment, judicial and other matters. Therefore, it is requested that the delay in filing of appeal before the Hon'ble ITAT in this case may kindly be condoned. The undersigned will be more cautious and this act will not be ....

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....k to the present case of the appellant, the following dates are relevant for the reference: S.No. Particulars Date 1. Date of third party search [Kuldeep Bishnoi Group] 23.07.2019 2. Date of recording of Satisfaction note by the AO of the searched person and third person (AO is same in both the cases) 26.03.2022 3. Date of notice u/s 153C 29.03.2022 7.5 Considering the above stated factual matrix, the reference date of search and seizure operation in case of appellant being other person as per 1st proviso to the sub section 1 to the Section 153C of the I.T. Act, 1961 shall be 29.03.2022 and hence previous year of search and seizure operation shall be 2021-22. Considering the previous year 2021-22....

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.... 1. "Whether on the facts and under the circumstances of the case and in law, the Ld. CIT(A) was justified in relying upon the judgment of Hon'ble Delhi High Court in the case of PCIT, Central-1, Delhi vs. Ojjus Medicare Pvt. Ltd. (ITA No.52 of 2024), even when the Revenue has filed a SLP against this decision of the Hon'ble Delhi High Court? 2. 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 u/s 153C(1) of Income tax Act, 1961, have to be calculated six years prior to the AY in which satisfaction note was recorded by concerned Assessing Officer or seized material pertaining to the non-searched person was handed over to the A....