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2024 (1) TMI 356 - AT - Income TaxValidity of assessment u/s 153C - date of recording of satisfaction - HELD THAT:- As date of search – 22.03.2012 (A.Y. 2012-13) and Date of recording of satisfaction u/s 153C – 18.11.2013 (A.Y. 2014-15), thus on going through the judgments of Hon’ble jurisdictional High Court and Jasjit Singh [2023 (10) TMI 572 - SUPREME COURT] AND RRJ Securities Ltd [2015 (11) TMI 19 - DELHI HIGH COURT] we have no hesitation to hold that the Assessments made for A.Y. 2006-07 and A.Y. 2007-08 u/s 153C consequent to the satisfaction note recorded on 18.11.2013 are outside the scope of Section 153C of the Income Tax Act, 1961 and hence, the assessments are treated as void ab initio. Decided against revenue.
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