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2019 (7) TMI 1374 - HC - Income TaxAssessment u/s 153C - notice u/s. 153C was barred by limitation - validity of notice u/s 153C - HELD THAT:- The coordinate bench in ANILKUMAR GOPIKISHAN AGRAWAL VERSUS ACIT, [2019 (6) TMI 746 - GUJARAT HIGH COURT] took the view that the writ applications were maintainable. With regard to the second question, the Court took the view that the Legislature has specifically made the amended provisions of Section 153C applicable with prospective effect from 01.06.2015. The Court held that if such amended provisions are not made applicable to the searches carried out prior to 01.06.2015, they would affect the substantive rights of the persons who are brought within the ambit of Section 153C of the Act by virtue of such amendment. So far as the third question is concerned with regard to the limitation, the Court took the view that when the statute itself provides for an alternative period of limitation, merely because the period of limitation is provided under the first part has elapsed; it cannot be said that the notices were barred by the limitation on such ground. Assessment Order has been passed u/s 153C the same is also quashed and set aside
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