2026 (9) TMI 845

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....espondent : Shri Manab Adak, Sr. DR ORDER PER YOGESH KUMAR U.S., JUDICIAL MEMBER: This Appeal is filed by the Assessee against the order of the NFAC, Delhi ('Ld. CIT(A)' for short) dated 03.03.2026, passed u/s 250 of the Income Tax Act, 1961 ("the Act", for short) for the Assessment Year 2015-16. 2. There is a delay of 25 days in filing the captioned Appeal. The Assessee filed an appli....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....al. 4. The Learned Counsel for the Assessee at the outset submitted that the Assessment year under consideration being 2015-16, in view of the Revenue conceded before the Supreme Court in the case of Union of India & Ors. Vs. Rajeev Bansal reported in 2024 SCC OnLine SC 2693, that 'the notice issued for Assessment year 2015-16 were time barred'. Thus, submitted that the Assessment order and the....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....arred by time in the light of the view taken by the Hon'ble Supreme Court in the case of Union of India& Ors. Vs. Rajeev Bansal (2024 SCC OnLine SC 2693)'. Further, the Hon'ble Supreme Court once again, while disposing the batch of cases, i.e., Income Tax Officer & Anr. Vs. Sri Sai Kumar Mateti reported in 2026(5) TMI 855-SC,observed as under: - "3. This batch of civil appeals comprising ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... 5. There is no quarrel that if the instant cases are found to pertain to Assessment Year 2015-16, then the impugned notices are liable to be struck down outrightly in terms of the concession on behalf of the Department recorded in paragraph 19(f) of Rajeev Bansal (supra) and reiterated before us by the leamed Additional Solicitor General of India. 6. However, if it is found that th....