2026 (5) TMI 470

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....amdeo, CIT(DR) ORDER PER M. BALAGANESH, A. M.: 1. The appeal in ITA No.9183/Del/2025 for AY 2016-17, arise out of the order of the Commissioner of Income Tax (Appeals)-26, New Delhi [hereinafter referred to as 'ld. CIT(A)', in short] dated 11.09.2025 against the order of assessment passed u/s 153C r.w.s. 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') dated 15.12....

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....ein was recorded by the ld AO of the assessee on 24.06.2022 for initiation of proceedings u/s 153C of the Act in the hands of the assessee for the six assessment years including AY 2016-17. The Hon'ble Supreme Court in the case of CIT vs Jasjit Singh reported in 458 ITR 437 (SC) had held that to initiate the proceedings u/s 153C of the Act and the time limit of six assessment years is to be comput....

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.... 153C of the Act for AY 2016-17 as it was beyond the period of 6 years by placing reliance on the aforesaid decisions. The ld CIT(A) by placing reliance on the decision of the Hon'ble Jurisdictional Delhi High Court in the case of Ojjus Medicare referred supra, the ld AO could have reopened the case of the assessee only for AYs 2017-18 to 2022-23 only and that the case of the AY 2016-17 falls outs....