W.p.(C)/17895/2024 Of Nivedan Bharadwaj v. Assistant Commissioner Of Income Tax Central Circle-19, & Ors

$~14. *IN THE HIGH COURT OF DELHI AT NEW DELHI+W.P.(C)17895/2024&CMAPPL.76182/2024,CMAPPL.76183/2024NIVEDAN BHARADWAJ.....PetitionerThrough:Mr. Nitin Gulati, Ms. Reena Gandhi,Advs.versusASSISTANT COMMISSIONER OF INCOME TAXCENTRAL CIRCLE-19, & ORS......RespondentsThrough:Mr. Debesh Panda, SSC with Ms.ZehraKhan,JSCandMr.Vikramaditya, JSC. CORAM:HON'BLE THE ACTING CHIEF JUSTICEHON'BLE MR. JUSTICE TUSHAR RAO GEDELAO R D E R%24.12.2024 1.The petitioner has filed the present petition impugning the noticedated 15.09.2023 (hereafter the impugned notice) under Section 153C of theIncome Tax Act, 1961 (hereafter the Act) as well as the notice under Section142(1) of the Act, inter alia, on the ground that the impugned notice isbarred by limitation. The impugned notice was issued on 15.09.2023 inrespect of assessment year 2014-15. 2.The learned counsel appearing for the Revenue fairly states that thecontentions advanced by the petitioner are correct and the impugned noticeis beyond the period of limitation. 3.The satisfaction note of the Assessing Officer for searched person wasrecorded on 23.08.2023, which is relevant to the assessment year 2024-25.The petitioner has set out a tabular statement in his objections to theimpugned notice indicating the block of six years in respect of which assessments could be re-opened under Section 153C of the Act. The saidtabular statement is set out below:“ ” 4.The learned counsel for the Revenue concurs with the abovesubmissions. Accordingly, the impugned notice is set aside. 5.The petition is allowed in the aforesaid terms. Pending applicationsalso stand disposed of. VIBHU BAKHRU, ACJ DECEMBER 24, 2024 N.Khanna TUSHAR RAO GEDELA, J