Beyond Six Years, Beyond Jurisdiction: Revenue Appeal Fails u/s 153C

ACIT Vs Pooja Gupta (ITAT Delhi) The Delhi ITAT “F” Bench, in ACIT v. Pooja Gupta (ITA No. 3739/Del/2025, AY 2014-15; order dated 29.12.2025), has dismissed the Revenue’s appeal and upheld the order of the CIT(A) deleting the assessment framed u/s 153C. The Tribunal noted that the CIT(A) had rightly relied on the jurisdictional Delhi High Court judgment in PCIT v. Ojjus Medicare Pvt. Ltd. (465 ITR 101) to hold that the assessment year under consideration fell beyond the permissible six assessment years contemplated u/s 153C r.w.s. 153A. The Revenue failed to bring on record any contrary ...