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2020 (2) TMI 570 - AT - Income TaxAssessment framed u/s 153C - Period of limitation - block period for initiation of proceedings - HELD THAT:- AO recorded satisfaction on 29.05.2017 and determined the block period as 2010-11 to 2015-16 taking into consideration the date of search. In our opinion, as in terms of the decision of Hon’ble High Court of Delhi in the case of RRJ Securities Ltd. [2015 (11) TMI 19 - DELHI HIGH COURT] the date of recording of satisfaction is to be construed as the AO having jurisdiction to assess the searched person u/s 153C of the Act. Hon’ble High Court of Delhi in the case of Sarwar Agency Pvt. Ltd. [2017 (8) TMI 733 - DELHI HIGH COURT] decline to admit the substantial question of law raised by the Revenue challenging the decision in the case of RRJ Securities Pvt. Ltd. Therefore, we find no infirmity in the order of CIT(A) and it is justified and we completely agree with the reasons recorded by the CIT(A) in his order in para no 6 which is reproduced herein above. Ground nos. 1 and 2 raised by the Revenue are dismissed.
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