2026 (5) TMI 1773

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....rikant Namdeo, CIT(DR) ORDER PER M. BALAGANESH, A. M.: 1. The appeal in ITA No.9181/Del/2025 for AY 2011-12, arises out of the order of the Commissioner of Income Tax (Appeals)-30, New Delhi [hereinafter referred to as 'ld. CIT(A)', in short] dated 24.09.2025 against the order of assessment passed u/s 153A of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') dated 31.03.2022....

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....2022 for the Assessment Year 2011-12 also. The Hon'ble Madras High 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....

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....td Vs. Union of India in WPO No. 438 of 2021 dated 28.12.2023. The ld CIT(A) duly appreciated the contentions of the assessee and by following the aforesaid decisions of the Hon'ble High Court including the Hon'ble Jurisdictional High Court held that the assessment order framed for AY 2011-12 as bad in law, as it was beyond the period of 10 years. Since, the decision has been rendered by following....