+ W.p.(C) 3983/2025 Cm Appl v. Assistant Commissioner Of Income Tax, Circle Int Tax 1(1)(2) & Anr
High Court
10 Jul 2025 In favour of: Assessee
Forum / Bench
High Court · dhcdb
Parties
+ W.p.(C) 3983/2025 Cm Appl v. Assistant Commissioner Of Income Tax, Circle Int Tax 1(1)(2) & Anr
Date of order
10 Jul 2025
Assessment year(s)
—
Outcome
Allowed
Case summary
In + W.p.(C) 3983/2025 Cm Appl v. Assistant Commissioner Of Income Tax, Circle Int Tax 1(1)(2) & Anr, the High Court (2025) allowed the appeal under Section 153A, Section 153C of the Income-tax Act. The decision went in favour of the assessee.
Issue: 4.The petitioner has set out a tabular statement reflecting the blockperiod of ten years that could be possibly be covered by the impugned noticeissued under Section 153C read with Section 153A of the Act.The saidtabular statement is reproduced below: 5.Undisputedly, the question whether the impugne...
Decision: 7.The petition is allowed in the aforesaid terms
Summary auto-generated from the order below — read the full judgment for the complete reasoning.
Sections referenced in this judgment
The order — as passed by the High Court
$~66
IN THE HIGH COURT OF DELHI AT NEW DELHI+W.P.(C) 3983/2025 CM APPL. 18511/2025 CM APPL. 18512/2025CM APPL. 39554/2025NEERAJ BHARADWAJ.....PetitionerCM APPL. 39554/2025NEERAJ BHARADWAJ.....Petitioner
.....PetitionerThrough:Mr. Sachit Jolly, Senior AdvocatewithMr.NilayGupta,Mr.AbhyudayaShankarBajpai,Mr.Sohum Dua and Ms. Mansha Anand,Advocates.withMr.NilayGupta,Mr.AbhyudayaShankarBajpai,Mr.Sohum Dua and Ms. Mansha Anand,Advocates.
versus
ASSISTANT COMMISSIONER OF INCOME TAX,CIRCLE INT TAX 1(1)(2) & ANR.
.....RespondentsThrough:Mr. Debesh Panda, SSC Ms. ZehraKhan, Mr. Vikramaditya Singh, JSCsMs Anauntta Shankar Ms RavichaSharma, and Ms Delphina Shinglai,Advocates.Khan, Mr. Vikramaditya Singh, JSCsMs Anauntta Shankar Ms RavichaSharma, and Ms Delphina Shinglai,Advocates.
CORAM:
HON'BLE MR. JUSTICE VIBHU BAKHRUHON'BLE MR. JUSTICE TEJAS KARIAO R D E R
%
10.07.2025
1.The petitioner has filed the present petition, inter alia, impugning the
notice dated 24.06.2024 [impugned notice] issued under Section 153C ofthe Income Tax Act, 1961 [the Act] in respect of the Assessment Year 2014-15.
2.It is contended on behalf of the Revenue that the impugned noticewas issued pursuant to the satisfaction note dated 06.07.2023 recorded bythe Assessing Officer .
3.In view of the above, it is apparent that the impugned notice has beenissued beyond the period of the limitation. The maximum period of ten yearsfor which the assessments could be reopened are required to be computed
from the end of the assessment year relevant to the Financial Year , inwhich the satisfaction note is recorded.
4.The petitioner has set out a tabular statement reflecting the blockperiod of ten years that could be possibly be covered by the impugned noticeissued under Section 153C read with Section 153A of the Act.The saidtabular statement is reproduced below:
5.Undisputedly, the question whether the impugned notice has beenissued beyond the period of limitation is covered by the earlier decision ofthis Court in The Pr. Commissioner of Income Tax-Central-1 v. OjjusMedicare Pvt. Ltd : Neutral Citation: 2024:DHC:2629-DB.
6.In view of the above, the present petition is allowed. The impugnednotice and further proceedings continued thereto is set aside.
7.The petition is allowed in the aforesaid terms. The pendingapplications are disposed of.
VIBHU BAKHRU, J
JULY 10, 2025/M
TEJAS KARIA, J
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