Separate Events Cannot Be Clubbed for ₹50 Lakh Reopening Threshold: ITAT Delhi

DCIT Vs Maharashtra Seamless Limited (ITAT Delhi)

Summary: The Income Tax Appellate Tribunal, Delhi, dismissed the Revenue’s appeals in DCIT Vs Maharashtra Seamless Limited and quashed the notices issued under Section 148. The decisive finding was that alleged cash expenditure relating to three separate furniture/interior-work orders could not be aggregated as expenditure on a single event or occasion under Section 149(1A). The escaped income identified in the approval material was ₹13 lakh, and the unexplained cash expenditure for each individual event did not exceed ₹50 lakh. Consequently, the conditions for reopening beyond three years under Section 149(1)(b), read with Section 149(1A), were not satisfied. The assessee’s cross-objections became academic and were dismissed without adjudication on their merits.

The common order concerns Revenue appeals ITA Nos. 3102 and 3103/Del/2026 and the assessee’s C.O. Nos. 272 and 273/Del/2026 against CIT(A)-27, New Delhi’s orders dated 31 December 2025. The opening narrative identifies AYs 2013-14 and 2014-15, and the later discussion applies the first appeal’s reasoning to the second year. However, the introductory table contains inconsistent assessment-year entries, including AY 2015-16, which are retained in the reproduced order. For the first year, the company originally filed its return on 29 October 2013 declaring income of ₹107,11,01,660 under the normal provisions and book profit of ₹1,95,95,10,306 under Section 115JB for MAT. The original scrutiny assessment dated 4 January 2017 determined income at ₹1,10,82,62,525.

A search on 9 February 2022 at the premises of the interior contractor, described as Perform Interiors Pvt. Ltd. in much of the supplied text and Proform Interiors Pvt. Ltd. elsewhere, led to seizure of a hard disk. It contained an Excel workbook titled “all accounts statement (current client) dated 13.08.2019”. According to the Assessing Officer, sheets relating to the assessee recorded cheque payments and cash payments that were absent from its books. A Section 148 notice was issued on 31 March 2023 after approval; one passage recording the assessee’s submissions instead refers to 30 March 2023. In response, the assessee filed a return on 29 April 2023 declaring ₹1,13,72,75,394. The reassessment determined income at ₹1,40,69,97,490.

The additions/disallowances comprised alleged unexplained cash expenditure under Section 69C, delayed employees’ EPF/ESI contributions of ₹46,09,079, disallowance of deduction under Section 80-IA of ₹6,61,73,736, and a disallowance at 2% of purchases amounting to ₹22,70,81,146. The supplied text prints the Section 69C amount as “8,71,0000/-”, states an aggregate of ₹29,87,34,961 in the narrative and ₹29,87,34,931 in the table. Those figures are reproduced without reconciliation. The CIT(A) admitted additional grounds challenging limitation and held the reassessment invalid. The assessee’s sixteen cross-objection grounds supported that order and also challenged the additions/disallowances.

The Revenue argued that the CIT(A) had read the first proviso to Section 149 only partly. Since the information originated from a third-party search, the pre-amendment Section 153C framework also had to be considered, rather than only the old six-year limit for Section 148 notices. It submitted that the extended ten-year period could cover AY 2013-14 where reopening occurred in FY 2022-23. The assessee relied on Rajeev Bansal, contending that the old six-year period had expired on 31 March 2020 and the TOLA extension ended on 30 June 2021. Independently, it stressed that the approval memo quantified escapement at only ₹13 lakh, below the ₹50 lakh requirement.

The assessee further explained that the alleged ₹13 lakh payments in FYs 2012-13 and 2013-14 related to Quote No. 2230 for ₹26 lakh. Other payments concerned Quote Nos. 2990 and 2833. These were three separate transactions and events occurring at different times, rather than one event whose expenditure could be aggregated across years. The Tribunal examined the reasons recorded for reopening and found that the Assessing Officer had treated cash payments against the three orders as a single event when invoking Sections 149(1)(b) and 149(1A). It held that Section 149(1A) contemplates aggregation across previous years where the investment in an asset or expenditure relates to the relevant event or occasion; it did not permit these three distinct orders to be combined into one event.

On the first proviso to Section 149, the Tribunal regarded the CIT(A)’s reasoning as only partly correct because the third-party search context required consideration of the former Section 153C provisions. Referring to CIT v. Jasjeet Singh, as cited in the supplied order, and Dinesh Jindal v. ACIT, it discussed computation with reference to handing over seized material. In Dinesh Jindal, the Delhi High Court had computed the ten-year block with reference to the notice dated 30 March 2023, ending at AY 2014-15 and leaving AY 2013-14 outside it. The reproduced High Court passages also discuss Ojjus Medicare on the relationship between Sections 149, 153A and 153C. They mention the pending challenge in Deeksha Holding Limited and expressly leave that issue open.

Ultimately, although the Tribunal did not fully agree with the CIT(A)’s reasons, it upheld the result because the ₹50 lakh condition was not met for any individual event and the separate events could not be aggregated under Section 149(1A). It quashed the Section 148 notice and dismissed the Revenue’s grounds. On the parties’ admission that the second year involved identical facts, the same reasoning was applied mutatis mutandis and its notice was also quashed as barred by limitation. Both Revenue appeals and both cross-objections were dismissed. The underlying additions were not adjudicated on merits because the cross-objections had become academic. The order was pronounced on 18 September 2026.

Cases Discussed

• Union of India & Ors. v. Rajeev Bansal — Civil Appeal No. 8629/2024 and connected matters, decision dated 3 October 2024 (Supreme Court). Relied upon by the CIT(A) and the assessee on limitation under the old and amended reassessment regimes; the Tribunal did not fully accept the CIT(A)’s reasoning.
• Dinesh Jindal v. ACIT — W.P.(C) No. 11164/2023, decision dated 27 May 2024 (Delhi High Court). Discussed for the ten-year block computation and exclusion of AY 2013-14; paragraphs 17–20 are reproduced in the order.
• PCIT v. Ojjus Medicare Pvt. Ltd. — ITA No. 52/2024 and connected matters, decision dated 3 April 2024 (Delhi High Court). Paragraphs 108–109 appear in the reproduced Dinesh Jindal extract concerning Sections 149, 153A and 153C.
• CIT v. Jasjeet Singh — [2024] (6) TMI 75 (SC), as cited in the supplied order (Supreme Court). Cited for reckoning the third-party assessment period with reference to handing over seized material.
• Deeksha Holding Limited v. ACIT, Delhi & Anr. — W.P.(C) No. 1023/2024 (Delhi High Court)

FULL TEXT OF THE ORDER OF ITAT DELHI

The captioned appeals are filed by Revenue and Cross-objections filed by the assessee against the different orders passed by Ld. Commissioner of Income Tax (A)-27, New Delhi [“Ld. CIT(A)”] u/s 250 of the Income Tax Act, 1961 [“the Act”] arising out of different assessment orders pertaining to Assessment Years 2013-14 & 2014-15 respectively tabulated as under:-

2. Before us, both the parties have stated that the facts involved in all these appeals are common, therefore, they are taken together and decided by a common order.

3. Briefly stated the facts of the case are that the assessee is a company and filed its return of income on 29.10.2013, declaring total income of INR 107,11,01,660/- under normal provisions of Act and book profit of INR 1,95,95,10,306/- was declared u/s 115JB of the Act for the purpose of MAT. The case of the assessee was selected for scrutiny and assessment was completed u/s 143(3) of the Act vide order dated 04.01.2017 wherein total income of the assessee was assessed at INR 1,10,82,62,525/-. Thereafter, a search and seizure operation was conducted u/s 132 in the case of M/s. Perform Interiors Pvt. Ltd. on 09.02.2022. The AO observed that during the course of search conducted in the case of M/s. Perform Interiors Pvt. Ltd., one hard disk was found and seized, containing data in the shape of Excel work book titled as “all accounts statement (current client) dated 13.08.2019”. In the said Excel work book, some Excel Sheets were found which according to the AO, relates to the transactions carried out by the assessee with M/s. Perform Interiors Pvt. Ltd. and contained details of certain payment made in cash as well as through cheque and the cash payments were not recorded in the books of accounts. Therefore, proceedings u/s 147 were initiated by issue of notice u/s 148 on 31.03.2023 after taking approval from the Competent Authority. In response, the assessee had filed return of income on 29.04.2023, declaring total income of INR 1,13,72,75,394/-. The AO thereafter, completed re-assessment proceedings and assessed the total income at INR 1,40,69,97,490/- by making following additions/disallowances, totaling to INR 29,87,34,961/-:

4. Against the said order, assessee preferred and appeal before the ld. CIT(A), before whom assessee has taken additional Grounds of appeal, challenging the legality of the re-assessment proceedings on the ground of limitation. Ld. CIT(A) had allowed the additional Grounds of appeal and held as re-assessment proceedings as invalid on the ground of limitation.

5. Aggrieved by the order of ld. CIT(A), the Revenue is in appeal before the Tribunal by taking following Grounds of appeal mentioned in the appeal memo:-

1. “Whether the Ld. CIT(A) has erred in the facts and in law by ignoring the fact that the notice issued u/s 148 of the Act is not barred by limitation as per the decision laid down in the case of Sh. Rajeev Bansal.

2. Whether on the facts and circumstances of the case, Ld. CIT(A), Delhi, has erred in allowing the appeal by quashing the order u/s 147 dated 31.03.2024 and notice u/s 148 dated 31.03.2023 without appreciating the fact that the phrase at that time mentioned in proviso I to section 149 refers to 1st day of April, 2021.

3. Whether on the facts and circumstances of the case, Ld. CIT(A), Delhi, has erred in quashing the order u/s 147 dated 31.03.2024 and notice u/s 148 dated 31.03.2023 for reassessment pertaining to AY 2013-14 treating the same as time barred by wrongly interpreting the first proviso to section 149(1)(b) of the Act which clearly states that if no notice could have been issued before the commencement of Finance Act, 2021 w.e.f. 01.04.2021 as per the then provisions of sec. 148 OR sec. 153A OR sec. 153C, then the notice for reopening cannot be issued at present

4. Whether on the facts and circumstances of the case, Ld. CIT(A), ignored this statutory position and considered the facts only partially as the AY 2013-14 falls squarely within the extended 10-year block under the old section 153A, meaning it is perfectly covered by the first proviso to the amended section 149 of the Act

5. The Order of the Honble CIT(A), Delhi is erroneous and not tenable in law and on facts.

6. The appellant craves to add, alter OR amend any/all of the grounds of appeal before OR during the course of the hearing of the appeal.”

6. The assessee also filed cross objection wherein the assessee has raised Cross-objection Nos. 1 to 16 which are in support of the order of ld. CIT(A) and further challenged the disallowances/additions made by the AO.

7. All the Grounds of appeal taken by the Revenue are against the order of ld. CIT(A) holding the re-assessment proceedings as barred by limitation by following the order of Hon’ble Supreme Court in the case of Rajeev Bansal. The Revenue further challenged the action of ld. CIT(A) in holding that ld. CIT(A) has not considered the first proviso to section 149(1) of the Act in its entirety and thus, all the Grounds of appeal are taken together for consideration.

8. In the instant case, as observed above, the proceedings u/s 147 of the Act were initiated by issue of notice u/s 148 on 31.03.2023, copy placed at pages 60 to 61 of Paper Book (PB). It is observed that said notice was issued based on the information found or requisitioned u/s 132 of the Act in the case of M/s. Perform Interiors Pvt. Ltd. where AO framed an opinion that such material was pertained to the assessee and income as found noted in the said seized material has escaped assessment. It is further observed that search in the case of M/s. Perform Interiors Pvt. Ltd. was carried out on 09.02.2022 thus, it was the period where the amended provisions of section 149 of the Act were applicable i.e. post 01.04.2021. Before going further, the provisions of section 149(1) as applicable to the assessment years under appeal are reproduced as under:-

[Time limit for notice.

(1) No notice under section 148 shall be issued for the relevant assessment year,—

(a) if three years have elapsed from the end of the relevant assessment year, unless the case falls under clause (b);

27[(b) if three years, but not more than ten years, have elapsed from the end of the relevant assessment year unless the Assessing Officer has in his possession books of account or other documents or evidence which reveal that the income chargeable to tax, represented in the form of—

(i) an asset;

(ii) expenditure in respect of a transaction or in relation to an event or occasion; or

(iii) an entry or entries in the books of account, which has escaped assessment amounts to or is likely to amount to fifty lakh rupees or more:]

Provided that no notice under section 148 shall be issued at any time in a case for the relevant assessment year beginning on or before 1st day of April, 2021, if 28[a notice under section 148 or section 153A or section 153C could not have been issued at that time on account of being beyond the time limit specified under the provisions of clause (b) of sub-section (1) of this section or section 153A or section 153C, as the case may be], as they stood immediately before the commencement of the Finance Act, 2021:

Provided further that the provisions of this sub-section shall not apply in a case, where a notice under section 153A, or section 153C read with section 153A, is required to be issued in relation to a search initiated under section 132 or books of account, other documents or any assets requisitioned under section 132A, on or before the 31st day of March, 2021:

29[Provided also that for cases referred to in clauses (i), (iii) and (iv) of Explanation 2 to section 148, where,—

(a) a search is initiated under section 132; or

(b) a search under section 132 for which the last of authorisations is executed; or

(c) requisition is made under section 132A,

after the 15th day of March of any financial year and the period for issue of notice under section 148 expires on the 31st day of March of such financial year, a period of fifteen days shall be excluded for the purpose of computing the period of limitation as per this section and the notice issued under section 148 in such case shall be deemed to have been issued on the 31st day of March of such financial year:

Provided also that where the information as referred to in Explanation 1 to section 148 emanates from a statement recorded or documents impounded under section 131 or section 133A, as the case may be, on or before the 31st day of March of a financial year, in consequence of,—

(a) a search under section 132 which is initiated; or

(b) a search under section 132 for which the last of authorisations is executed; or

(c) a requisition made under section 132A,

after the 15th day of March of such financial year, a period of fifteen days shall be excluded for the purpose of computing the period of limitation as per this section and the notice issued under clause (b) of section 148A in such case shall be deemed to have been issued on the 31st day of March of such financial year:]

Provided also that for the purposes of computing the period of limitation as per this section, the time or extended time allowed to the assessee, as per show-cause notice issued under clause (b) of section 148A or the period during which the proceeding under section 148A is stayed by an order or injunction of any court, shall be excluded:

Provided also that where immediately after the exclusion of the period referred to in the immediately preceding proviso, the period of limitation available to the Assessing Officer for passing an order under clause (d) of section 148A 30[does not exceed seven days], such remaining period shall be extended to seven days and the period of limitation under this sub-section shall be deemed to be extended accordingly.

Explanation.—For the purposes of clause (b) of this sub-section, “asset” shall include immovable property, being land or building or both, shares and securities, loans and advances, deposits in bank account.

9. Before us, ld. CIT DR for the Revenue vehemently supported the order of the AO and submits that ld. CIT(A) while holding the re-assessment order passed as barred by limitation has considered the provision of section 149(1) in part. As per ld. CIT DR, the case of the assessee is re-opened on the basis of documents found and seized from the possession of third party i.e. M/s. Perform Interiors Pvt. Ltd. and therefore, the pre-amended provisions of seciton153C of the Act are applicable and can be invoked in the instant case and thus, extended the parties of 10 years is applicable in the instant case. He thus, submits that the action of ld. CIT(A) in holding that if the case of the assessee could not be reopened u/s 148 under pre-amended provisions where the limit of 06 years from the end of the relevant year is provided and therefore the order of Ld.CIT(A) is correct to such extent however, the proceedings u/s 153C could be initiated for the extended period and thus the AO has rightly initiated the proceedings u/s 148 of the Act. Ld.CIT Dr submits that the assessee’s case was re-opened in FY 2022-23 and therefore, period of 10 years would be available upto AY 2013-14 and accordingly, he prayed that the order of ld. CIT(A) on this score should be reversed.

10. On the other hand, ld.AR for the assessee vehemently supported the order of ld. CIT(A) and submits that in the instant case, ld. CIT(A) has followed the order of Hon’ble Apex Court in the case of Rajeev Bansal wherein vide para 19, the Hon’ble Apex Court has held that for issue of notice u/s 148 for AY 201314, time limit of Six years from the end of relevant assessment years had expired on 31.03.2020 and as per TOLA, limitations was extended upto 30.06.2021. However, notice u/s 148 was issued on 30.03.2023 therefore, the same is barred by limitation. Regarding the argument raised by the ld. CIT DR that the extended period of 10 years as provided u/s 153C of the Act is applicable, ld.AR submits that case of the assessee was re-opened for escapement of income. Ld.AR submits that as per the approval memo placed at page 76 to 77 of the Paper Book, total income escaped assessment was quantified at INR 13.00 Lakhs and the case of the assessee is being re-opened by applying the provision of section 149(1)(b) of the Act. Ld. AR submits that as per section 149(1)(b) of the Act where notice u/s 148 is issued between the period exceeding three years but before the expiry of Ten years, the income chargeable to tax which has escaped assessment as in the form of assets should be likely to amount of INR 50.00 Lakhs or more. Ld.AR submits that once the satisfaction is recorded of the escapement of income of INR 13.00 Lakhs, the provision of section 149(1)(b) of the Act could not be invoked in the instant case. Ld.AR further submits that AO further applied provision of section 149(1A) of the Act which are not applicable in the instant case as alleged payments of INR 13.00 Lakhs was made in FY 2012-13 & 2013-14 with respect to the transaction against the order in quote No.2230 of INR 26.00 Lakhs and the remaining payments were with respect to the transactions in Quote No.2990 & 2833 therefore, there are three separate transactions carried out which constitutes three separate events and all the three events cannot be clubbed together and more particularly, when they are happened in different time zone. Ld.AR thus requested for the confirmation of the order of ld. CIT(A).

11. Heard the contentions of both the parties and perused the material available on record. In the instant case, proceedings u/s 147 were initiated on the basis of the information found and seized from the possession of M/s. Perform Interiors Pvt. Ltd. during the course of search carried out at its business premises wherein certain excel sheets were found and seized. According to those excel sheets, cash payments were made by the assessee on different dates in respect of different orders for furniture, interior etc. The AO as per the reasons recorded for re-opening, placed at pages 62 onwards of PB, treated the cash payments in three different orders for different items as a single event and total cash payment of made was taken the basis for re-opening the assessment by applying the provision of section 149(1)(b) r.w.s 149(1A) of the Act. Before going further, we first refer the provisions of section 149 of the Act [as existed for the relevant AY applicable for the search conducted on or after 01.04.2021], which reads as under:-

149. [(1A) “Notwithstanding anything contained in sub-section (1), where the income chargeable to tax represented in the form of an asset or expenditure in relation to an event or occasion of the value referred to in clause (b) of sub-section (1), has escaped the assessment and the investment in such asset or expenditure in relation to such event or occasion has been made or incurred, in more than one previous years relevant to the assessment years within the period referred to in clause (b) of sub-section (1), a notice under section 148 shall be issued for every such assessment year for assessment, reassessment or recomputation, as the case may be.]

(2) The provisions of sub-section (1) as to the issue of notice shall be subject to the provisions of section 151.]”

12. Further in terms of provision of section 149(1A) of the Act, the cumulative figure of various Assessment years should be taken as escaped income represent as asset or expenditure which relates to an event or occasion that has occurred in more than one assessment year falling within the period referred in clause (b) of sub-section (1) of section 149, in such case notice u/s 148 shall be issued for each such Assessment Year separately for reassessment.

13. As observed above, the alleged incriminating Excel Sheets retrieved from the digital data seized during the course of search in the case of M/s. Proform Interiors Pvt. Ltd. containing details of transaction entered into by the assessee with it, there were three different quotes for three different order thus they should be treated as three different events or occasion for which cash payments were made by the assessee on different dates and all the three events are in different time zone and therefore they cannot be considered as one event or occasion for the purpose of invoking the provision of section 148 of the Act.

14. Ld.CIT(A) while holding the notice issued u/s 148 of the Act as barred by limitation has considered the limitations provided in First Proviso to section 149(1)(b), according to which if no notice u/s 148 could be issued under preamended era, no notice could be issued in the amended section 149 of the Act. However, such observations of ld. CIT(A) are partially correct as the case of the assessee was re-opened based on the information found from the possession of third party therefore, under pre-amended provisions, proceedings u/s 153C should have been initiated in the case of the assessee. As per the judgement of Hon’ble Supreme Court in the case of CIT v. Jasjeet Singh [2024] (6) TMI 75 (SC) followed by Hon’ble Jurisdictional High Court in the case of Dinesh Jindal v. ACIT [WP (C) No. 11164 of 2023, dated 27-5-2024], wherein the Hon’ble High Court has held that the date of handed over the material is to be taken the date of search in the case of third party and the period of 10 years has to be counted from such date. In the case of Dinesh Jindal (supra), the Hon’ble High Court under identical circumstances, wherein the case of the assessee was re-opened u/s 148 of the Act by issue notice dated 30.03.2023 had computed the period of 10 years which ends upto AY 2014-15 and held the AY 2013-14 has fallen beyond the block period of 10 years u/s 153C r.w.s. 153A of the Act. The relevant observations of the Hon’ble Court as contained in para 17 to 20 are as under:-

17. “Insofar as the two Provisos to Section 149 (1) are concerned, we had in Ojjus Medicare Private Limited observed as follows:

“108. We also find ourselves unable to countenance the submissions based upon the two Proviso’s placed in Section 149 for the following reasons. It must at the outset be noted that Section 149 regulates the time within which a notice under Section 148 may be issued.

It thus neither ventures nor attempts to regulate the search assessment powers that are available to be invoked in terms of Sections 153A or 153C. Secondly, although the First Proviso (and to the extent that it included a reference to Sections 153A and 153C). came to be introduced by virtue of Finance Act. 2022 (Act 6 of 2022] with retrospective effect from 01 April 2021. the non obstante clause in Sections 153A and 153C was left untouched. Of equal significance is the fact that that Sections 153A and 1530 of their own stipulate no period within which a notice initiating search assessment may be issued. We further find that the bar created by virtue of the First Proviso is in relation to Sections 153A and 153C as they stood immediately before the commencement of Finance Act. 2021. The concept of relevant assessment year and the block of ten AYs’ was made part of those provisions way back in 2017 itself and thus formed an integral part of those provisions as on 01 April 2021.

109. Any doubt that could have possibly been harboured is in any case stand dispelled by the Second Proviso to Section 149 and which unambiguously proclaims that the provisions of that sub-section would not apply to searches conducted or requisitions made prior to 31 March 2021. Thus, all searches conducted prior to 31 March 2021 remained unimpacted by the Provisos’ placed in Section 149 of the Act. These statutory amendments to Section 149 would have to be read in juxtaposition with Section 153C(3) which brought the curtains down upon search assessments liable to be made in accordance with the trinity, provisions with effect from 01 April 2021. This since Parliament by virtue of Finance Act. 2021 had merged the original reassessment power as well as those which may be predicated upon a search within the ambit of Section 148 and its family of provisions.”

18. Bearing in mind the aforesaid, the computation of the “relevant assessment year from the date of the impugned Section 148 notice dated 30 March 2023 would be as follows:

19. It is therefore ex facie evident that AY 2013-14 falls beyond the ten-year block period as set out under Section 153C read with Section 153A of the Act. Consequently, the impugned notice dated 30 March 2023 has been issued beyond limitation and is liable to be quashed and set aside on this score alone. All consequential actions pursuant to the impugned notice would thus meet a similar fate.

20. On the prayer pertaining to reading down of Explanation 2(iv) to Section 148 of the Act, we note that the said issue along with a challenge to the vires of the said Explanation is being considered by us in WP(C) 1023/2024-Deeksha Holding Limited v. ACIT, Delhi & Anr. Thus, we refrain from answering this question in the instant writ petition. The same is consequently kept open to be urged by the assessee in an appropriate case and if circumstances so warrant.”

15. Further, as observed above, even if the Revenue’s contention is accepted that the case of the assessee could be re-opened as per provisions of section 149(1)(b) of the Act, the income escaped assessment is less than INR 50.00 Lakhs i.e. [INR 13.00 Lakhs only]. Therefore even though, the provision of section 149(1)(b) of the Act are not applicable in the instant case where case has been re-opened after the expiry of 03 years and before the end of 10 years from the end of the year in which search is taken place. Accordingly, though we are not in agreement with the reasons given by the ld. CIT(A) while holding the reassessment proceedings as barred by limitations however, as observed above, in the instant case, there are three different events and cumulative payment in cash of unexplained expenditure for each individual event was not more than Rs. 50.00 lacs, thus, the provisions of section 149(1A) of the Act cannot be invoked in the instant case. Therefore for this reason, the notice issued u/s 148 of the Act beyond the period of three year from the end of the relevant assessment year based on the satisfaction that income has escaped assessment for various assessment years in the shape of unexplained expenditure cumulatively more than Rs. 50.00 lacs as per 149(1A) of the Act is incorrect and consequent notice issued u/s 148 is hereby quashed. Accordingly, all the Grounds of appeal raised by the Revenue are dismissed.

16. Since we have dismissed the appeal of the Revenue and quashed the notice issued u/s 148 therefore, Cross-objection filed by the assessee became academic and hence, not adjudicated.

17. In the result, appeal of the Revenue is dismissed and Cross-objection field by the assessee is also dismissed.

18. Now we take appeal of the Revenue in ITA No.3103/Del/2026 and Crossobjection of the assessee in C.O. No.273/Del/2026 for Assessment Year 201415.

19. Before us, both the parties have fairly admitted that facts in this year are identical to the facts of the AY 2013-14 where in ITA No.3102/Del/2026 for AY 2013-14 in the above-mentioned paras, we have held the notice issued u/s 148 of the Act as barred by limitations. Thus, by respectfully following the observations as made in ITA No.3102/Del/2026 for AY 2013-14 which are applicable Mutatis Mutandis in the present case, the notice issued u/s 148 of the Act is hereby, quashed as barred by limitation. Accordingly, all the Grounds of appeal raised by the Revenue are dismissed.

20. Since we have dismissed the appeal of the Revenue and quashed the notice issued u/s 148 therefore, Cross-objection filed by the assessee became academic and hence, not adjudicated.

21. In the result, appeal of the Revenue is dismissed and Cross-objection filed by the assessee is also dismissed.

22. In the final result, both appeals of the Revenue in ITA Nos. 3102 & 3103/Del/2026 and Cross-objections of the assessee in C.O. Nos. 272 & 273/Del/2026, all are dismissed.

Order pronounced in the open Court on 18.09.2026.