TMI Blog2017 (9) TMI 1593X X X X Extracts X X X X X X X X Extracts X X X X ..... rson’, was effective from 1st April 2017 it should be viewed as clarificatory and therefore applicable even to the case on hand Held that:- It is seen that as far as AY 2010-11, in terms of Section 153 C, the assessment had to be completed by 31st December 2012. Even the satisfaction note was prepared only on 8th August 2013. The Court is unable to agree with the revenue's submission. It is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ORDER 1. This is an appeal under Section 260A of the Income Tax Act, 1961 ( the Act ) filed by the Revenue against the order dated 29th June, 2016 passed by the Income Tax Appellate Tribunal ( ITAT ) in ITA No. 1930/Del/2015 for the Assessment Year ( AY ) 2010-11. 2. While admitting this appeal on 6th February, 2017, the following question of law was framed for consideration: Did the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nce of the satisfaction note, the date of the filing of the return, the date of centralising of the assessments and the date of the final order of assessment were not clear when the matter was earlier heard along with the aforementioned batch of appeals. He states that as far as the Assessee s assessment for this year (AY 2010-11) is concerned, the time period within which the assessment had to be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... catory and therefore applicable even to the case on hand. 6. The Court is unable to agree with the said submission. It is plain that the amendment to section 153 C of the Act is prospective. In the present case the assessment for AY 2010-11 had abated by the time the satisfaction note was prepared by the AO of the Assessee. The said asseement could not be reopened in the absence of tangible mat ..... X X X X Extracts X X X X X X X X Extracts X X X X
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