Delhi HC Upholds Deletion of Tax Addition; Section 153C Notice Beyond Six-Year Limit

PCIT Vs Pragun Finance Pvt. Ltd. (Delhi High Court) The Delhi High Court has dismissed an appeal filed by the Principal Commissioner of Income Tax (PCIT), thereby affirming the deletion of a substantial tax addition made against Pragun Finance Pvt. Ltd. The ruling reinforces the strict jurisdictional and temporal limitations governing assessments under Section 153C of the Income Tax Act, 1961, especially concerning the retrospective application of subsequent statutory amendments. The central issue before the Court was the validity of a notice issued under Section 153C for the Assessment Year (...