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Section 153C Time-Bar Checkmate: AYs Beyond 10 Years Cannot Be Touched

Case Law Details

Case Name
DCIT Vs Arun Gupta (ITAT Delhi)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2011-12
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DCIT Vs Arun Gupta (ITAT Delhi) Revenue filed appeals against CIT(A)’s order deleting protective additions made in the hands of Arun Gupta. AO had made protective additions in Assessee’s hands & substantive additions in M/s Transline Technologies Ltd. Assessee relied on Tribunal’s order in DCIT Vs Transline Technologies Ltd. (ITA 3693/Del/2025, order dated 07.11.2025), wherein Tribunal—following Delhi HC judgment in Ojjus Medicare Pvt Ltd (161 taxmann.com 160)—held that AYs 2011-12 & 2012-13 fall beyond the permissible 10-year block u/s 153C, reckoned from the date of satisfa...
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