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2014 (11) TMI 1012 - AT - Income TaxValidity of assessment u/s 153C - whether in the case of assessee there was no pending proceedings as on the date of search hence there was no question of abatement of proceedings? - contention of the ld. CIT(DR) on the contrary remained that the reference of proviso 1 of section 153C is only in relation to the second proviso to sub-section 1 of section 153A which speaks about the abatement of the pending proceedings of six assessment years and not regarding the assessment of the preceding six assessment years which will be the same as in section 153A as well as in section 153C - Held that:- Similar view has been expressed by the Delhi Bench of the Tribunal in the case of V.K. Fiscal (2013 (11) TMI 1589 - ITAT DELHI) holding that the date of receiving of the seized documents would become the date of search and six years period would be reckoned from this date. - Decided in favour of the assessee.
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