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Judgment
This assessee’s appeal for Assessment Year 2010-11 arises against the C IT(A)/NFAC, De lhi’ s DIN & order No. ITBA/NFAC/S/250/2025-26/1079692656(1) dated 18.08.2025, in proceed ings u/s 147 of the Income Tax Act, 1 961 (in short “the Act”).
Heard both the p arties at length. Case file perused.
It transpires during the course of hear ing that ther e arises the fir st and foremost issue of validity of the impugned section 147 r.w.s. 254 r .w.s. 144B asse ssment framed by the learned assessing authority on 18.03.2024. This is for the precise reason that the tribunal’s earlier learned co-ordinate bench had restored the matter vide remand directions on 11.02.2022.
Faced with this situation, the Revenue could hardly dispute that going by the statutory limitation in such remand directions involv ing time limit of 12 months from the end of the financial year thereof u/ s 153(3) r.w. Proviso, the learned Assessing Officer’s assessment framed on 18.03.2024 happens to be a time barr ed one. Quashed accordingly.
All other plead ings betwee n the parties stand rendered academic.
This assessee’s appeal is allowed in above terms.