2026 (5) TMI 1768

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.... Dang, CA For the Revenue : Shri Shrikant Namdeo, CIT(DR) ORDER PER M. BALAGANESH, A. M.: 1. The appeals in ITA No.9188 and 9187/Del/2025 for AYs 2010-11 and 2013-14, arise out of the order of the Commissioner of Income Tax (Appeals)-25, New Delhi [hereinafter referred to as 'ld. CIT(A)', in short] dated 15.09.2025 and 30.09.2025 against the order of assessment passed u/s 153A/ 153C of....

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.... 19.10.2019. Consolidated Satisfaction note in the case of the assessee herein was recorded by the ld AO of the assessee on 10.05.2022 for initiation of proceedings u/s 153C of the Act in the hands of the assessee for the ten assessment years i.e. AYs 2010-11 to 2020-21. 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 proceedi....

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....l HC). The assessee argued that the ld AO could not have initiated proceedings u/s 153C of the Act for AYs 2010-11 and 2013-14 as it was beyond the period of 10 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 ....

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....inclined to follow the decision of the Hon'ble Jurisdictional Delhi High Court. We find that the ld DR through his written submissions is only trying to impress upon the bench by bringing on record how the 6 years or 10 years reckoning need to be understood by relying on the principles of interpretation of statutes, but when the same issue had already been considered and addressed by the Hon'ble J....