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2017 (10) TMI 626 - AT - Income TaxValidity of assessment u/s 153C - period of limitation - whether date of recording of satisfaction u/s 153C of the Act may be taken as date of handling over of seized documents? - Held that:- Date of receiving the seized documents and other evidences should be taken as 29.01.2013. By virtue of first proviso to section 153C, date of initiation of search for computing six assessment years has to be counted as if date of search is 29.01.2013. Six assessment years covered uls 153C would be A.Y. 2007-08 to A. Y. 2012-13. Therefore, impugned assessment years 2006-07 cannot covered within six assessment years as envisaged u/s 153C. Accordingly, Ld. CIT(A) rightly held that the impugned assessment for A. Y. 2006-07 is time barred and not covered u/s. 153C of I.T. Act. Accordingly, the impugned assessment order was rightly held annulled, which does not need any interference on our part, hence, we uphold the same. Appeal of the Revenue is dismissed.
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