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2014 (10) TMI 359 - KARNATAKA HIGH COURTPassing of block assessment – Block assessment made - whether the block assessment order was passed in time or not – Held that:- The assessee contended that the search was conducted on 14.11.1996 in pursuance of an authorization and a mahazar was drawn – in C.RAMAIAH REDDY VS. ASSISTANT COMMISSIONER OF INCOME-TAX [2010 (9) TMI 862 - Karnataka High Court] – it has been held that the period of limitation starts on the date on which the last of authorization has been executed and not when the authorized officer states that the search is finally concluded - putting a prohibitory order u/s 132 (3) does not elongate the starting point of limitation - there was only one authorization dated 05.11.1996 in pursuance of which search was conducted on 14.11.1996 - the search was continued on the two consecutive dates and it ended on 16.11.1996, the block assessment orders should have been passed on or before 30.11.1997 - Whereas the block assessment order is passed on 29.01.1998 which is clearly barred by law of limitation - the block assessment order passed is liable to be set aside as barred by limitation – Decided against revenue.
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