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Judgment
PER ANUBHAV SHARMA, JM:
These are appeals preferred by the Revenue against the orders dated 14.02.2025 of the Commissioner of Income-tax (Appeals)-24, New Delhi (hereinafter referred to as the ld. First Appellate Authority or ‘the Ld. FAA’ for short) in Appeals No.CIT(A), Delhi-24/10199/2013-14 and No.CIT(A), Delhi-24/10823/2015-16 arising out of the appeals before it against the orders dated 31.03.2023 passed u/s 153C r.w.s. 143(3) of the Income Tax Act, 1961 (hereinafter referred as ‘the Act’) by the DCIT, Central Circle-07, New Delhi (hereinafter referred to as the Ld. AO).
Primarily, the grounds raised by the Revenue appear to be superfluous as the ld.CIT(A), following the decision of the Hon’ble Delhi High Court in CIT v. RRJ Securities Ltd. [2015] 62 taxmann.com 391 (Delhi) and the judgement of the Hon’ble Supreme Court in CIT v. Jasjit Singh (2025) 476 ITR 15, has held that the present two assessment years do not fall in the block period of six assessment years as mentioned in section 153C of the Act. No case of any harmonious interpretation of section 153A of the Act and 153C of the Act is left out to be decided by this bench. The ld.CIT(A) has duly taken into consideration the facts as reflected in the impugned order to hold that the assessments for the years in hand could not have been made by invoking the provisions of section 153C of the Act. Thus there is no substance in grounds. The appeals are dismissed.