2026 (8) TMI 1726

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....r 2009-10. 2. At the time of hearing, ld. AR of the assessee with the permission of the Bench brought to our notice relevant facts on record. In this regard, he brought to our notice page 145 of the paper book, the impugned order passed by the ld. CIT (A), Delhi-23, and brought to our notice the relevant findings at para 5 of the said order wherein ld. CIT (A) clearly brought on record that the core issue under consideration is notice issued under section 148 of the Income-tax Act, 1961 (for short 'the Act') dated 30.11.2023 for the impugned year is time barred. The relevant facts are, the Finance Act, 2021 had substantially amended the reassessment procedure u/s 147 to 151 w.e.f. 01.04.2021. Under the old regime i.e. prior to 01.04.2021....

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....h the above findings, he relied on the decision of Hon'ble Delhi High Court in the case of ARN Infrastructure India Limited vs. ACIT (WP (C) 1892/2024). 3. Aggrieved with the above order, Revenue is in appeal before us. 4. At the time of hearing, ld. AR brought to our notice that there was a search and seizure operation u/s 132 of the Act carried out in Chadha Group of cases and based on the material found in their case, proceedings u/s 153C of the Act was initiated in the case of the assessee and accordingly assessment order was passed on 28.03.2014. Aggrieved, assessee preferred an appeal before the ld. CIT(A), Delhi-30 and after considering the detailed submissions of the assessee, ld. CIT (A) decided the issue in favour of the ass....