2026 (5) TMI 478

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....ant Namdeo, CIT (DR) ORDER PER M. BALAGANESH, A. M.: 1. The appeal in ITA Nos. 9070 and 9071/Del/2025 for AYs 2014-15 and 2015-16, arise out of the order of the Commissioner of Income Tax (Appeals)-25, Delhi [hereinafter referred to as 'ld. CIT(A)', in short] dated 10.03.2024 for AY 2014-15 and dated 10.03.2024 against the order of assessment passed u/s 153C of the Income-tax Act, 1961 (h....

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....ng that the year under consideration fall outside the prescribed block period and accordingly no assessment could be validly framed thereon. This is a preliminary issue going to the root of the matter and hence, we proceed to take up the same first for adjudication. 4. We have heard the rival submissions and perused the material available on record. The search in the case of Alankit group was c....

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....gh Court in the case of AR Safiullah Vs. ACIT in CMP (MD) Nos. 3513, 3515 and 3516 of 2021 dated 24.03.2021 had categorically held that the Explanation 1 to Section 153A of the Act clearly provide for the manner of computation of 10 assessment years. Later the very same view was also endorsed by Hon'ble Jurisdictional Delhi High Court in the case of PCIT Vs. Ojjus Medicare Pvt. Ltd reported in 161....

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.... Similar view was also endorsed by Hon'ble Calcutta High Court in the case of R.B. Jewellers Pvt. Ltd Vs. Union of India in WPO No. 438 of 2021 dated 28.12.2023. 6. The ld DR before us filed his written submissions stating that the decision of Hon'ble Jurisdictional Delhi High Court in the case of Ojjus Medicare Pvt Ltd is challenged by the revenue by way of Special Leave Petition before the Ho....