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Judgment
These three appeals by the Revenue and two Cross Objection (C.O.) by the assessee are directed against the order both dated 31.12.2025 of the Ld. Commissioner of Income Tax (Appeals)-27, New Delhi [hereinafter referred to as ‘Ld. CIT(A)] arsing out of the order dated both 31.03.2024 passed by Joint Commissioner of Income-tax (OSD), Central Circle-20, New Delhi [hereinafter referred to as ‘AO’) passed u/s 147 r.w.s. 143(3) of the Income Tax Act, 1961 ([hereinafter referred to as ‘the Act’) pertaining to Assessment Years 2013-14 and 2014-15 respectively.
The Revenue has raised the following grounds of appeal (ITA No.-3250/Del/2026):
“1.Whether the Ld. CIT(A) has erred in the facts and in law by ignoring the fact that the notice issued u/s 148 of the Act is not 1 barred by limitation as per the decision laid down in the case of Sh. Rajeev Bansal
2.Whether on the facts and circumstances of the case, Ld. CIT(A), Delhi, has erred in allowing the appeal by quashing the order u/s 147 dated 31.03.2024 and notice u/s 148 dated 31.03.2023 without appreciating the fact that the phrase at that time mentioned in proviso I to section 149 refers to 1st day of April, 2021
3.Whether on the facts and circumstances of the case, Ld. CIT(A), Delhi, has erred in quashing the order u/s 147 dated 31.03.2024 and notice u/s 148 dated 31.03.2023 for reassessment pertaining to AY 2013-14 treating the same as time barred by wrongly interpreting the first proviso to section 149(1)(b) of the Act which clearly states that if no notice could have been issued before the commencement of Finance Act, 2021 w.e.f. 01.04.2021 as per the then provisions of sec. 148 OR sec. 153A OR sec. 153C, then the notice for reopening cannot be issued at present.
4.Whether on the facts and circumstances of the case, Ld. CIT(A), ignored this statutory position and considered the facts only partially as the AY 2013-14 falls squarely within the extended 10-year block under the old section 153A, meaning it is perfectly covered by the first proviso to the amended section 149 of the Act
5.The Order of the Hon’ble CIT(A), Delhi is erroneous and not tenable in law and on facts
6.The appellant craves to add, alter OR amend any/all of the grounds of appeal before OR during the course of the hearing of the appeal.”
The Revenue has raised the following grounds of appeal (ITA No.-3251/Del/2026):
“1.Whether the Ld. CIT(A) has erred in the facts and in law by ignoring the fact that the notice issued u/s 148 of the Act is not barred by limitation as per the decision laid down in the case of Sh. Rajeev Bansal
2.Whether on the facts and circumstances of the case, Ld. CIT(A), Delhi, has erred in allowing the appeal by quashing the order u/s 147 dated 31.03.2024 and notice u/s 148 dated 31.03.2023 without appreciating the fact that the phrase at that time mentioned in proviso I to section 149 refers to Ist day of April, 2021
3.Whether on the facts and circumstances of the case, Ld. CIT(A), Delhi, has erred in quashing the order u/s 147 dated 31.03.2024 and notice u/s 148 dated 31.03.2023 for reassessment pertaining to AY 2013-14 treating the same as time barred by wrongly interpreting the first proviso to section 149(1)(b) of the Act which clearly states that if no notice could have been issued before the commencement of Finance Act, 2021 w.e.f. 01.04.2021 as per the then provisions of sec. 148 OR sec. 153A OR sec. 153C, then the notice for reopening cannot be issued at present
4.Whether on the facts and circumstances of the case, Ld. CIT(A), ignored this statutory position and considered the facts only partially as the AY 2013-14 falls squarely within the extended 10-year block under the old section 153A, meaning it is perfectly covered by the first proviso to the amended section 149 of the Act
5.The Order of the Hon’ble CIT(A), Delhi is erroneous and not tenable in law and on facts
6.The appellant craves to add, alter OR amend any/all of the grounds of appeal before OR during the course of the hearing of the appeal.”
The Revenue has raised the following grounds of appeal (ITA No.-3252/Del/2026):
“1.Whether the Ld. CIT(A) has erred in the facts and in law by ignoring the fact that the notice issued u/s 148 of the Act is not barred by limitation as per the decision laid down in the case of Sh. Rajeev Bansal.
2.Whether on the facts and circumstances of the case, Ld. CIT(A), Delhi, has erred in allowing the appeal by quashing the order u/s 147 dated 31.03.2024 and notice u/s 148 dated 31.03.2023 without appreciating the fact that the phrase at that time mentioned in proviso I to section 149 refers to 1st day of April, 2021.
3.Whether on the facts and circumstances of the case, Ld. CIT(A), Delhi, has erred in quashing the order u/s 147 dated 31.03.2024 and notice u/s 148 dated 31.03.2023 for reassessment pertaining to AY 2014-15 treating the same as time barred by wrongly interpreting the first proviso to section 149(1)(b) of the Act which clearly states that if no notice could have been issued before the commencement of Finance Act, 2021 w.c.f. 01.04.2021 as per the then provisions of sec. 148 OR sec. 153A OR sec. 153C, then the notice for reopening cannot be issued at present
4.Whether on the facts and circumstances of the case, Ld. CIT(A), ignored this statutory position and considered the facts only partially as the AY 2014-15 falls squarely within the extended 10-year block under the old section 153A, meaning it is perfectly covered by the first proviso to the amended section 149 of the Act
5.The Order of the Honble CIT(A), Delhi is erroneous and not tenable in law and on facts.
6.The appellant craves to add, alter OR amend any/all of the 6 grounds of appeal before OR during the course of the hearing of the appeal.”
The Assessee has raised the following grounds of appeal (C.O. No.-276/Del/2026):
“1.On the facts and circumstances of the case, the notice issued under section 148 and assessment order passed under section 147 r.w.s 143(3) by the AO are illegal, invalid, without jurisdiction, barred by limitation and hence liable to be quashed
2.On the facts and circumstances of the case, the notice issued under section 148 of the Income Tax Act, 1961 ("Act") and consequent assessment order under section 147 r.w.s 143(3) without complying with the statutory conditions and the procedure prescribed under the law are bad and liable to be quashed.
3.On the facts and circumstances of the case, the notice issued under section 148 is illegal, invalid, without jurisdiction and barred by limitation as the same was issued beyond the time limit prescribed under first proviso to section 149(1) read with fourth proviso to section 153A read with section 153C(1) of the Act.
4.On the facts and circumstances of the case, the reopening of the reassessment proceedings and notice issued under section 148 of the Act is invalid, without jurisdiction, illegal and unsustainable as the same has been issued by invoking the provisions of section 149(1A) of the Act for aggregating the alleged escaped income, which is not applicable to the present facts of the case of the assessee.
5.On the facts and circumstances of the case, the reassessment order passed by the Joint Commissioner of Income Tax is illegal, without jurisdiction and hence unsustainable in law, as the Joint Commissioner of Income Tax (OSD) is not an assessing officer within the meaning of the section 2(7A) of the Act, 1961.
6.On the facts and circumstances of the case, the reassessment order passed stands vitiated and liable to be quashed as the same has been passed under the directions of the Additional Commissioner of Income Tax, Central Range-05, New Delhi.
7.On the facts and circumstances of the case, the reassessment order passed stands vitiated and liable to be quashed as the JCIT has failed to exercise his independent quasi-judicial discretion and has abdicated his authority, thereby rendering the assessment proceedings illegal and without lawful justification.
8.On the facts and circumstances of the case, the reassessment order passed under section 147 r.w.s 143(3) of the Act is illegal, invalid, without jurisdiction and unsustainable as the AO has assumed jurisdiction over the assessee without there being any valid order passed under section 127 of the Act
9.On the facts and circumstances of the case, the notice issued under Section 148 of the Income Tax Act, 1961 (Act) and consequent assessment order under section 147 r.ws 143(3) of the Act is invalid, void-ab-initio, without jurisdiction as the same has been passed without following the specific provisions of section 148A of the Act
10.(i) On the facts and circumstances of the case, the assessment order passed by the AO under section 147 r.ws 143(3) of the Act is invalid, illegal and unsustainable as the same has been passed without obtaining the valid prior statutory approval from prescribed authority under section 1488 of the Income Tax Act, 1961
(ii)That the purported approval is illegal, invalid mechanical and has been given without application of mind
11.On the facts and circumstances of the case, the case has been reopened on the basis of search conducted on third party and therefore proceedings initiated under Section 148 of the Act and the reassessment order passed under the said section are illegal, bad and liable to be quashed as the same has been made without recording any valid satisfaction and without taking any valid prior statutory approval under Explanation 2 to section 148 of the Act and proviso to section 148A of the Act
12.(i) On the facts and circumstances of the case, the reassessment order under section 147 r. w s 143(3) is illegal and void ab initio as the same has been passed despite the fact that the notice under section 148 has been issued without obtaining valid statutory prior approval from the specified authority as provided under section 151 of the Act.
(ii)That the purported approval is illegal, invalid mechanical and has been given without application of mind.
13.On the facts and circumstances of the case, the notice under section 148 of the Act is illegal, without jurisdiction and barred by limitation as the same has been issued without complying to the statutory conditions prescribed under section 149(1)(b) of the Income Tax Act.
14.On the facts and circumstances of the case, the reassessment order passed by the under section 147 r.w.s 143(3) is illegal, invalid, without jurisdiction and hence liable to be quashed as the same has been reopened on the basis of the information which are mere change of opinion as the issue was already examined during the course of assessment proceedings under Section 143(3) of the Act.
15.On the facts and circumstances of the case, the additions made in the assessment order in the absence of any incriminating material found during the course of search is illegal, without jurisdiction and unsustainable.
16.(i) On the facts and circumstances of the case, the disallowance of Rs. 17,61,36,535-made in the assessment order on estimation basis as 2% of total purchases of Rs.880,68,26,768/-claimed by the assessee treating the same as unverifiable is invalid, illegal and unsustainable.
(ii)That the abovesaid addition made in the assessment order on an estimated basis, which is illegal, arbitrary, unjustified, and unsustainable in law.
17.On the facts and circumstances of the case, the abovesaid addition has been made ignoring the settled position of law that when sales have not been doubted corresponding purchases cannot be treated as non-genuine.
18.(i) On the facts and circumstances of the case, the abovesaid addition has been made by rejecting the books of the assessee which is illegal, invalid and contrary to the facts on record.
(ii)That the abovesaid addition has been made in the assessment order despite the fact that assessee has been maintaining regular books of accounts, stock register and financial statement are audited as per law and nothing adverse has been pointed out by the AO.
19.On the facts and circumstances of the case, the abovesaid addition made in the assessment order is illegal and unsustainable as the same has been made without conducting any independent enquiry under section 133(6)/131 of the Act during the course of reassessment proceedings.
20.On the facts and circumstances of the case, the disallowance of Rs. 24,41,591/- made in the reassessment order on account of employee's contribution to EPF/ESI by invoking the section 36(1)(va) of the Act is illegal, invalid, unsustainable and liable to be deleted.
21.(i) On the facts and circumstances of the case, the addition of Rs. 4,29,000/- made in the assessment order on account of alleged cash expenditure under section 69C r.w.s 115BBE of the Act by arbitrarily attributing 33% of the total alleged cash expenditure to the assessee and the balance 67% to M/s Maharashtra Seamless Ltd. which is illegal, arbitrary, unjustified, and unsustainable in law
(iii)That the abovesaid addition made ignoring the contention of the assessee that the no such alleged cash payment has been made by the assessee and provisions of section 69C are not applicable
22.On the facts and circumstances of the case, the abovesaid addition made in the assessment order is illegal and unsustainable as the same has been made on the basis of material collected and statement of third parties recorded at the back of the assessee without providing the copies of those statements and without providing the opportunity to cross examine those parties.
23.That the respondent craves leave to add, amend or alter any of the grounds of appeal.”
The Assessee has raised the following grounds of appeal (C.O. No.-2767Del/2026):
“1.. On the facts and circumstances of the case, the notice issued under section 148 and assessment order passed under section 147 r.w.s 143(3) by the AO are illegal, invalid, without jurisdiction, barred by limitation and hence liable to be quashed.
2.On the facts and circumstances of the case, the notice issued under section 148 of the Income Tax Act, 1961 ("Act") and consequent assessment order under section 147 r.wis 143(3) without complying with the statutory conditions and the procedure prescribed under the law are bad and liable to be quashed.
3.On the facts and circumstances of the case, the notice issued under section 148 is illegal, invalid, without jurisdiction and barred by limitation as the same was issued beyond the time limit prescribed under first proviso to section 149(1) read with fourth proviso to section 153A read with section 153C(1) of the Act.
4.On the facts and circumstances of the case, the reopening of the reassessment proceedings and notice issued under section 148 of the Act is invalid, without jurisdiction, illegal and unsustainable as the same has been issued by invoking the provisions of section 149(1A) of the Act for aggregating the alleged escaped income, which is not applicable to the present facts of the case of the assessee.
5.On the facts and circumstances of the case, the reassessment order passed by the Joint Commissioner of Income Tax is illegal, without jurisdiction and hence unsustainable in law, as the Joint Commissioner of Income Tax (OSD) is not an assessing officer within the meaning of the section 2(7A) of the Act, 1961.
6.On the facts and circumstances of the case, the reassessment order passed stands vitiated and liable to be quashed as the same has been passed under the directions of the Additional Commissioner of Income Tax, Central Range-05, New Delhi.
7.On the facts and circumstances of the case, the reassessment order passed stands vitiated and liable to be quashed as the JCIT has failed to exercise his independent quasi-judicial discretion and has abdicated his authority, thereby rendering the assessment proceedings illegal and without lawful justification
8.On the facts and circumstances of the case, the reassessment order passed under section 147 r.w.s 143(3) of the Act is illegal, invalid, without jurisdiction and unsustainable as the AO has assumed jurisdiction over the assessee without there being any valid order passed under section 127 of the Act.
9.On the facts and circumstances of the case, the notice issued under Section 148 of the Income Tax Act, 1981 (Act') and consequent assessment order under section 147 r.w.s 143(3) of the Act is invalid, void-ab-initio, without jurisdiction as the same has been passed without following the specific provisions of section 148A of the Act.
10.(i) On the facts and circumstances of the case, the assessment order passed by the AO under section 147 r.w.s 143(3) of the Act is invalid, illegal and unsustainable as the same has been passed without obtaining the valid prior statutory approval from prescribed authority under section 1488 of the Income Tax Act, 1961.
(ii)That the purported approval is illegal, invalid mechanical and has been given without application of mind.
11.On the facts and circumstances of the case, the case has been reopened on the basis of search conducted on third party and therefore proceedings initiated under Section 148 of the Act and the reassessment order passed under the said section are illegal, bad and liable to be quashed as the same has been made without recording any valid satisfaction and without taking any valid prior statutory approval under Explanation 2 to section 148 of the Act and proviso to section 148A of the Act
12.(1) On the facts and circumstances of the case, the reassessment order under section 147 r.w.s 143(3) is illegal and void ab initio as the same has been passed despite the fact that the notice under section 148 has been issued without obtaining valid statutory prior approval from the specified authority as provided under section 151 of the Act.
(ii)That the purported approval is illegal, invalid mechanical and has been given without application. of mind.
13 On the facts and circumstances of the case, the notice under section 148 of the Act is illegal, without jurisdiction and barred by limitation as the same has been issued without complying to the statutory conditions prescribed under section 149(1)(b) of the Income Tax Act
14.On the facts and circumstances of the case, the reassessment order passed by the under section 147 r.w.s 143(3) is illegal, invalid, without jurisdiction and hence liable to be quashed as the same has been reopened on the basis of the information which are mere change of opinion as the issue was already examined during the course of assessment proceedings under Section 143(3) of the Act
15.On the facts and circumstances of the case, the additions made in the assessment order in the absence of any incriminating material found during the course of search is illegal, without jurisdiction and unsustainable.
16.(i) On the facts and circumstances of the case, the disallowance of Rs. 17,94,88,925/- made in the assessment order on estimation basis as 2% of total purchases of Rs.897,44,46,280/- claimed by the assessee treating the same as unverifiable is invalid, illegal and unsustainable.
(ii)That the abovesaid addition made in the assessment order on an estimated basis, which is illegal, arbitrary, unjustified, and unsustainable in law.
17 On the facts and circumstances of the case, the abovesaid addition has been made ignoring the settled position of law that when sales have not been doubted corresponding purchases cannot be treated as non-genuine
18.(i) On the facts and circumstances of the case, the abovesaid addition has been made by rejecting the books of the assessee which is illegal, invalid and contrary to the facts on record
(ii)That the abovesaid addition has been made in the assessment order despite the fact that assessee has been maintaining regular books of accounts, stock register and financial statement are audited as per law and nothing adverse has been pointed out by the AO
19.On the facts and circumstances of the case, the abovesaid addition made in the assessment order is illegal and unsustainable as the same has been made without conducting any independent enquiry under section 133(6)/131 of the Act during the course of reassessment proceedings.
20 On the facts and circumstances of the case, the disallowance of Rs. 44,024/- made in the reassessment order on account of employee's contribution to EPF/ESI by invoking the section. 36(1)(va) of the Act is illegal, invalid, unsustainable and liable to be deleted.
21.(i) On the facts and circumstances of the case, the addition of Rs. 99,000/- made in the assessment order on account of alleged cash expenditure under section 69C r.w.s 115BBE of the Act by arbitrarily attributing 33% of the total alleged cash expenditure to the assessee and the balance 67% to M/s Maharashtra Seamless Ltd. which is illegal, arbitrary, unjustified, and unsustainable in law.
(iii)That the abovesaid addition made ignoring the contention of the assessee that the no such alleged cash payment has been made by the assessee and provisions of section 69C are not applicable.
22.On the facts and circumstances of the case, the abovesaid addition made in the assessment order is illegal and unsustainable as the same has been made on the basis of material collected and statement of third parties recorded at the back of the assessee without providing the copies of those statements and without providing the opportunity to cross examine those parties.
23.That the respondent craves leave to add, amend or alter any of the grounds of appeal.”
At the outset, it has been pointed out by the Ld. AR that ITA No. 3250/Del/2026 and ITA No. 3251/Del/2026 are same appeals filed twice. Accordingly, ITA No. 3251/Del/2026 being infructuous is hereby dismissed.
As common issues involving identical facts are there in both the appeals, these are being disposed off by a common order.
A.Y. 2013-14 ( ITA No. 3250/Del/2026 & C.O. 276/Del/2026)
Brief facts are that the assessee’s case were reopened on the basis of incriminating documents and evidences relating to it found during the course of a search u/s 132 conducted on M/s Proform Interiors Pvt. Ltd. on 09.02.2022. Based on the evidences regarding out- of-books cash sales by the searched entity to various clients, including the assessee, proceedings u/s 147 were initiated on 31.03.2023, requiring the assessee to furnish its return for A.Y. 2013-14. Return was filed on 28.04.2023 declaring total income of Rs. 12,19,67,884/-. After scrutiny, assessment order u/s 147 r.w.s. 143(3) dated 31.03.2024 was passed on assessed income of Rs. 30,12,50,280/- after making total addition of Rs. 17,90,07,126/-.
Aggrieved, the assessee preferred an appeal before CIT(A). Vide order dated 31.12.2025, appeal of the assessee was allowed by the CIT(A) on the ground of limitation with the following observations:
“5.11Thus, on the perusal of the above judgment and ratio laid down by the Hon'ble Supreme court in case of Rajeev Bansal(supra) and the Hon'ble Jurisdiction Delhi High Court in various case laws as discussed above, I am of the considered opinion that the first proviso to Section 149(1)(b) requires the determination of whether the time limit prescribed under Section 149(1)(b) of the old regime continues to exist for the assessment year 2021-2022 and before. Resultantly, a notice under आ Section 148 of the new regime cannot be issued if the period of six years from the end of the relevant assessment year has expired at the time of issuance of the notice. Hence, in present case in hand, notice u/s 148 of the Act issued on 31-03- 2023 is barred by limitation. Moreover, in this case as per discussion in para 18 at page no. 23 of the this order, in the judgment in case of Dinesh Jindal (supra), the Hon'ble Delhi High Court has held that AY-2013-14 also barred by limitation by period of limitation of 10 years.
5.12Therefore, after careful consideration of the above narrated facts, circumstances of the case and the submissions of the Appellant & Assessment Order and respectfully following the ratio of the judgments of the Hon'ble Apex Court and the Hon'ble Jurisdictional Delhi High Court, the Ld. Assessing Officer has wrongly assumed the jurisdiction u/s 147/148 of the Income Tax Act, 1961 by issuing the notice u/s 148 dated 31.03-2023 and thus, notice issued under section 148 of Act is barred by limitation & consequential reassessment proceeding made u/s 147 r.w.s. 143(3) of the Act is hereby quashed. Therefore, this additional ground of appeal is allowed.
6.With regard to other grounds of appeal, since the appeal of the appellant is allowed in respect of additional ground of appeal and notice under section 148 of Act & consequential reassessment proceeding are quashed, therefore, other grounds of appeal have become redundant and academic in nature, hence, not being adjudicated separately.”
Aggrieved with the order of CIT(A), the Revenue has filed the present appeal before the Tribunal while C.O. has been filed by the assessee.
We have heard the rival submissions and perused the material available on record. The Revenue contends that CIT(A) erred in ignoring the first proviso to section 149(1)(b) which states that after 1.4.2021, if a notice under earlier provisions of section 148 or 153A or 153C could not have been issued then the notice for reopening cannot be issued at present also.
On the other hand, Ld. AR has filed several decisions of the Hon’ble Jurisdictional High Court in support of his contentions and supporting the order of CIT(A).
Ld. AR has also filed the following chart to demonstrate that impugned notice was barred by limitation: -
He has further argued that the issue at hand stands covered by the decision of the Hon’ble jurisdictional High Court in the case of Dinesh Jindal vs. ACIT [2024] 469 ITR 32 (Del) in identical facts and circumstances, involving the same searched entity whereas the Hon'ble Delhi High Court held that, while applying the first proviso to section 149(1), the period of limitation has to be computed by giving full effect to the legal fiction contained in the first proviso to section 153C(1). Applying the said principle, the Hon'ble Court held that AY 2013-14 falls beyond the permissible block period and, therefore, the notice issued under section 148 was barred by limitation and liable to be quashed.
We have heard the rival submissions and perused the material available on record. We are of the considered view that the CIT(A) has correctly followed the binding decisions of the Hon’ble Jurisdictional High Court and has allowed the assessee’s appeal by a well-reasoned and speaking order. We, therefore, do not find any reason to interfere with the same. Accordingly, appeal of the Revenue is dismissed. Consequently, C.O. filed by the assessee is rendered infructuous and is also dismissed.
A.Y. 2014-15 ( ITA No. 3252/Del/2026 and C.O. No. 277/Del/2026)
For A.Y. 2014-15, also the Ld. DR has made identical arguments. On the other hand, Ld. AR has pointed out that in A.Y. 2014-15 even though it falls within the 10 years but beyond six years block, the allegation of escapement does not amount to Rs. 50 lakhs or more. The relevant submissions of the assessee in this regard are as under:
“8.The notice issued under section 148 for AY 2014-15 is barred by limitation and without jurisdiction. Although AY 2014-15 falls within the tenth assessment year reckoned from the deemed search year, it does not qualify as a "Relevant Assessment Year" within the meaning of the fourth proviso to section 153A. This is for the following independent reasons:
a. Extended period cannot be invoked as the statutory threshold of Rs. 50 lakhs as prescribed in Fourth Proviso to section 153A is not satisfied
9.The allegation of escapement for AY 2014-15 is merely Rs. 3,00,000, which is substantially below the statutory threshold of Rs. 50 lakhs prescribed under the fourth proviso to section 153A. Further, even if the alleged escaped income of all the relevant assessment years is aggregated, the aggregate still does not exceed Rs. 50 lakhs. Thus, the mandatory jurisdictional condition for invoking the extended block period remains unfulfilled.
10.The aforesaid issue is squarely covered by the judgment of the Hon'ble Delhi High Court in Pratishta Garg v. ITO, [2024] 164 taxmann.com 672 (Delhi) / 2024 (5) TMI 1681, wherein it has been held that satisfaction regarding the statutory threshold of Rs. 50 lakhs is a sine qua non for invoking the extended assessment period under the fourth proviso to section 153A. In the absence of such satisfaction. the notice itself is without jurisdiction and liable to be quashed.”
We have carefully considered the rival submissions and the material placed on record. We note that while initiating the proceedings, the AO has recorded the reasons and quantum of escapement as under:
“6.1It is seen from above that the assessee has made total cash payments of Rs. 92,23,500/- to M/s Proform Interiors during year under consideration. A breakup of all the cash payments made by the assessee company is also tabulated hereunder for the sake of clarity:
From the above table extracted from the assessment order, it is clear that the income alleged to have escaped assessment for A.Y. 2014-15 was only Rs. 3 lakhs and, therefore, extended period of 10 years was not applicable as the amount involved was below the threshold limit of Rs. 50 lakhs.
Accordingly, we found no merit in the appeal of the Revenue and the same is hereby dismissed. Resultantly, the C.O. filed by the assessee is rendered infructous and the same is also dismissed.
In the result, all the three appeals of the Revenue and the two C.Os. of the assessee are hereby dismissed.