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2021 (8) TMI 322 - AT - Income TaxAssessment u/s 153A - Assessment barred by limitation - Addition u/s. 68 on account of unexplained cash credits - documents/material belonging to the appellant were found during the course of search on PIL - HELD THAT:-The terminal date for determination of six preceding assessment years that would lay upon under section 153C read with section 153A of the Act would decidedly be the date of handing over of the documents. Here the satisfaction note recorded by the A.O, of M/s Prakash Industries Ltd. is 22.12.2014, as well as by the A.O. of the appellant is on 22.12.2014, which is to be taken as the date of handing over of documents and date. Six preceding assessment years begin with A.Y. 2009-10 and end with A.Y. 2014-15. It would be the date of handing over the documents or date of recording of satisfaction will be the date for determining the date for calculating the preceeding six assessment years is well settled by the judgement of RRJ Securities [2015 (11) TMI 19 - DELHI HIGH COURT] We hold that no assessment under section 153C could have been made in respect of A.Y. 2007-08 as it was clearly barred by limitation. Hence, there is no option but to annul the assessment and all consequent additions made in the assessment also stand deleted. - Decided in favour of assessee.
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