ITA 3985 & 3986/DEL/2026

Parties Involved

Facts Summary

The appeal in ITA Nos. 3985 & 3986/DEL/2026 for Assessment Years 2012-13 and 2013-14 arises from the order of the National Faceless Appeal Centre (NFAC), Delhi dated 03.12.2025 against the order of assessment passed by the Assessing Officer, ACIT, Central Circle-25, Delhi. The search operation under section 132 of the Income-tax Act, 1961 was carried out on 18.10.2019 in Alankit Group of cases. Certain documents belonging to the assessee were found and handed over to the AO of the assessee on 05.04.2022. The block period of 6 years or 10 years needs to be reckoned from AY 2023-24, being the year of search for the assessee. The years under consideration i.e. AY 2012-13 and 2013-14 would fall outside the block period and no valid assessments could be framed thereon under section 153C of the Act.…

Legal Issues

• 1. Whether the years under consideration fall outside the block period and accordingly no assessment could be validly framed thereon.

Judgment Outcome

Decided in favour of Revenue.

Precedents Relied Upon

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