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2019 (1) TMI 295 - AT - Income TaxApplicability of provisions of section 153(2A) - contention of the assessee was that through the orders of assessment was dated 30.12.2011, those orders were despatched only on 09.01.2012 through the Bangalore GPO through Speed Post to the assessee and the same was served on the assessee only on 10.01.2012 - period of limitation - whether the date of despatch has to be construed as the date of order of assessment and consequentially the orders of assessment have to be held as bad in law? - Held that:- It is undisputed that the order of assessment was despatched by the AO only on 09.01.2012 and that the last date of limitation for passing the order of assessment, pursuant to the directions of the Tribunal in all the three assessment years was 31.12.2011 as relying on M/S MAHARAJA SHOPPING COMPLEX VERSUS THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-1 (2) [2014 (10) TMI 880 - KARNATAKA HIGH COURT] the orders of assessment have to be held as barred by time and all the orders of assessment are therefore liable to be annulled and are hereby annulled. - decided in favour of assessee
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