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2022 (7) TMI 1444 - HC - Income TaxValidity of Assessment u/s 153A - Period of limitation - HELD THAT:- As rightly noted by the ITAT the requirement under Section 153B (1) is for the AO to make the assessment order within a period of twenty-one months from the end of the financial year in which the last of the authorization for the search under Section 132 of the Act was executed. In the present case, there is no doubt that the last date by which the assessment had to be made was 31st December, 2016. As further rightly noticed Section 153B (1) uses the expression “order of assessment” and not merely ‘assessment’. Therefore, the assessment order becomes an order only when in fact it is communicated and therefore the communication of the order had to be prior to the end of the limitation period. No error has been committed by the ITAT in allowing the Assessee’s appeal.
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