2026 (5) TMI 452

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....v, Advocate For the Revenue : Shri Mahesh Kumar, CIT-DR ORDER PER ANUBHAV SHARMA, JM: This appeal is preferred by the Revenue against the order dated 14.08.2025 of the Ld. Commissioner of Income-tax (Appeals)-25, New Delhi (hereinafter referred to as the First Appellate Authority or 'the ld. FAA' for short) in appeal No.10740/2014-15, filed before him against the order dated 26.03.2023....

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....evidences in the name of the assessee were also found, in whose case proceedings u/s 153C of the Act were therefore commenced. In view of the aforesaid, notice u/s 153C of the Act was issued on 30.12.2021 to the assessee. In response, the assessee filed Return of Income (RoI) on 21.01.2022 declaring total income of Rs. 22,59,770/-. Assessment order was subsequently passed by the AO on 26.03.2023 d....

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.... of six years preceding the assessment year relevant to the previous year in which the satisfaction note was drawn / notice u/s 153C issued. The period of six years that could be reopened by the AO thus terminates with the AY 2016-17. 5. Hon'ble Supreme Court in CIT vs. Jasjit Singh (2023) 458 ITR 423 (SC) and Hon'ble Delhi High Court decision in case of CIT Vs. RRJ Securities Ltd. (2016) 380 I....