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2019 (8) TMI 1340 - HC - Income TaxAssessment u/s 153C - period of limitation - HELD THAT:- Legislature has specifically made the amended provisions of Section 153C of the Act 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 by virtue of such amendment. So far as the third question is concerned with regard to the limitation, the Court in ANILKUMAR GOPIKISHAN AGRAWAL VERSUS ACIT [2019 (6) TMI 746 - GUJARAT HIGH 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 In case any notices u/s 153C which have been issued for assessment years beyond the six assessment years referred to herein above, such notices would be beyond jurisdiction as the same do not fall within the six assessment years as contemplated u/s 153A - Decided in favour of assessee.
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