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Assessment of Income of any other person - Section 153C - Income Tax - Ready Reckoner - Income TaxExtract Assessment of Income of any other person - Section 153C Limit for completion of assessment of other person referred to in section 153C [First and Second provisos to section 153B(1) Assessment of other person referred to in section 153C for Six assessment years for the relevant assessment year or years Assessment Year of search Period of search and seizure conducted: - Normal Period of Assessment/ Reassessment u/s 153B Period of Assessment/ Reassessment where a reference has been made to Transfer Pricing Officer u/s 92CA in course of proceedings u/s 153A Before 01.04.2018 21 months from the end of the financial year in which the last of the authorisations for search u/s 132 or for requisition u/s 132A was executed 33 months from the end of the financial year in which the last of the authorisations for search u/s 132 or for requisition u/s 132A was executed In FY 2018-19 18 months from the end of the financial year in which the last of the authorisations for search u/s 132 or for requisition u/s 132A was executed 30 months from the end of the financial year in which the last of the authorisations for search u/s 132 or for requisition u/s 132A was executed In FY 2019-20 onwards 12 months from the end of the financial year in which the last of the authorisations for search u/s 132 or for requisition u/s 132A was executed 24 months from the end of the financial year in which the last of the authorisations for search u/s 132 or for requisition u/s 132A was executed Where books of account or documents or assets seized or requisitioned are handed over u/s 153C to the AO having jurisdiction over such other person, whichever is later. Period of search and seizure conducted: - Normal Period of Assessment/ Reassessment u/s 153B Period of Assessment/ Reassessment where a reference has been made to Transfer Pricing Officer u/s 92CA in course of proceedings u/s 153A On or after 01.04.2018 9 months from the end of the financial year in which the last of the authorisations for search u/s 132 or for requisition u/s 132A was executed 21 months from the end of the financial year in which the last of the authorisations for search u/s 132 or for requisition u/s 132A was executed For AY 2021-22, where search has taken place during FY 2020-21 [Amendment w.e.f. AY 2022-23] EXTENDED The assessment in such cases for the AY 2021-22 shall be made on or before the 30.09.2022. The assessment in such cases for the AY 2021-22 shall be made on or before the 30.09.2022. Notes:- Before a notice u/s 153C could be issued, the Assessing Officer is required to arrive at a conclusive satisfaction that documents belong to a person other than searched person. The mere use of word 'satisfaction' in order or note, would not meet requirement of concept of satisfaction as used in section 153C . [Pepsi Foods (P.) Ltd. v ACIT 2015 (5) TMI 655 - DELHI HIGH COURT ]
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