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2022 (5) TMI 58 - GUJARAT HIGH COURTAssessment u/s 153C for the referred assessment years more particularly when the Limited Liability Partnership came into existence for the first time in 2016 - respondent submit that this Court, in exercise of its extraordinary jurisdiction under Article 226 of the Constitution may not interfere at the stage of Section 153C - HELD THAT:- Having heard the learned counsel appearing for the parties and having gone through the materials on record, we are of the view that we need not enter into any debate as regards the constitution or registration of the LLP. We say so because when the assessment orders are not passed for the A.Y. 2013-14, 2014-15, 2015-16 and 2016- 17 respectively, the matter ends over here. So far as 2017-18 and 2018-19 are concerned, as the assessment orders have already been passed, we decline to go into any other issues with respect to these two notices. In view of the aforesaid, this writ application succeeds in part. The impugned notices with respect to A.Y.2013-14, 2014-15, 2015-16 and 2016-17 are hereby quashed and set aside. So far as the assessment orders which have already been passed with respect to A.Y.2017- 18 and 2018-19, it shall be open for the writ applicant to file appropriate appeal in accordance with law.
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