Delhi HC Sets Aside 153C Proceedings for AY 2010-11 to 2013-14 Due to Limitation

Dhiresh Gupta Vs DCIT (Delhi High Court)

The petitioner challenged notices issued under Section 153C of the Income Tax Act for Assessment Years 2010-11 to 2013-14. It was contended that the satisfaction note of the Assessing Officer was dated 24.06.2022 and, if treated as the date of initiation of proceedings, the notices were barred by limitation. Reliance was placed on the Delhi High Court judgment in Pr. Commissioner of Income Tax Central-1 v. Ojjus Medicare Pvt. Ltd. The Department could not controvert the factual and legal position but stated that an SLP had been file

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