Sudhir Agrawal Vs DCIT (ITAT Delhi)
The Income Tax Appellate Tribunal (ITAT), Delhi, disposed of eight appeals filed by the assessee against the common order of the Commissioner of Income Tax (Appeals) dated 10.02.2026, arising from assessment orders dated 30.03.2023 passed under Section 153C of the Income-tax Act, 1961 for Assessment Years 2013-14 to 2020-21.
The proceedings originated from a search under Section 132 conducted on the Alankit Group, Shri Alok K. Agarwal, his son Ankit Agarwal and certain associates and key employees on 18.10.2019. During the search, incriminating material relating to the assessee was found. The assessee’s case was subsequently centralized under Section 127, notice under Section 153C dated 28.12.2021 was issued, followed by notices under Sections 143(2) and 142(1). After considering the assessee’s submissions, the Assessing Officer completed assessments under Section 153C on 30.03.2023 for all relevant assessment years. The CIT(A) upheld the assessments.
Before the Tribunal, the assessee primarily contended that the assessments under Section 153C were barred by limitation. Reliance was placed on the Tribunal’s decision in Ajay Gupta vs. DCIT dated 16.02.2026, wherein it was held that where the Assessing Officer of the searched person and the other person is the same, limitation commenced from the date of transfer under Section 127 when the records stood transferred to the common Assessing Officer.
