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ITA Nos.457/Del/2024 & Others

Case No: ITA Nos.457, 458, 551, 553, 552, 554/Del/2024 and 3809, 3816, 3810, 3859/Del/2023, C.O-42/Del/2024, ITA Nos. 981 to 985, 170, 171, 977, 978/Del/2024
Court: INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH ‘E’, NEW DELHI
Date: 3/12/2025

Parties Involved

appellantTeras Hotels & Resorts Pvt. Ltd.
respondentDCIT Central Circle –29, New Delhi
appellantTeras Ispat & Power Pvt. Ltd.
appellantTeras Steels Pvt. Ltd.
appellantUrjaa Metalics Pvt. Ltd.

Facts Summary

The captioned appeals arise from the orders of the Commissioner of Income Tax (Appeals)-30, New Delhi passed under s. 250 of the Income Tax Act, 1961, emanating from respective assessment orders passed by the Assessing Officer. The appeals involve a common legal point concerning the bar of limitation under s. 153(3) of the Act. A search and seizure operation under s. 132 of the Act was carried out, leading to assessments under s. 153A. The legitimacy of the additions/disallowances was challenged before the ITAT. The Co-ordinate Bench of the Tribunal set aside the assessment orders and remitted the issues for fresh adjudication. The assessment orders were re-framed under s. 153A r.w.s 254/143(3) of the Act, all dated 23.04.2021, and were challenged in the present appeals.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the assessment orders are barred by limitation under s. 153(3) of the Income Tax Act, 1961.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

4 precedents cited in this judgement.

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Version 2.0.1Last updated: October 2025
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