Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights July 2023 Year 2023 This

Assessment framed u/s 153A r.w.s 143(3) as barred by limitation ...


Tax Assessment u/s 153A Barred by Limitation; Invalid Reference to Swiss Info Blocks Extension Argument.

July 28, 2023

Case Laws     Income Tax     AT

Assessment framed u/s 153A r.w.s 143(3) as barred by limitation - We are of the considered view that the information called for by the department from Swiss authorities could not have been received by them for the period prior to 01.04.2011. Therefore, it would be a futile exercise to wait for such information, and that too, by an invalid reference. Therefore, in our considered opinion, the period of limitation could not be extended as claimed by the Revenue - AT

View Source

 


 

You may also like:

  1. Validity of assessment order passed u/s 153A r.w.s. 143(3) - Extension of period of limitation - reference made by the revenue to Swiss authorities - Since the reference...

  2. The HC held that the period of limitation for reopening assessments under Section 153C read with Section 153A must be calculated from the end of the assessment year...

  3. ITAT upheld CIT(A)'s decision that assessment order under s.143(3) r.w.s. 144C(3) r.w.s. 144B was time-barred. TPO reference under s.92CA(1) was made on 13.09.2021, with...

  4. Assessment u/s 153C/153A - Computation of the Relevant Assessment Years Block - Jurisdiction for Reopening Assessments - The Delhi High Court meticulously analyzed the...

  5. Introduction of block assessment provisions in cases of search u/s 132 and requisition u/s 132A for early finalization of search assessments, coordinated investigation,...

  6. The ITAT quashed assessment orders for AYs 2014-15 and 2015-16 as time-barred, finding that the AO's reference to special audit under s.142(2A) was void ab initio since...

  7. Assessment u/s 153A r.w.s. 153C - Block period - Period of limitation - Where two assessments may result, in the case of a searched entity and the related person, both...

  8. Substitution of new section for section 153B- Time limit for completion of assessment under section 153A. - The limitation for completion of assessment under section...

  9. Assessment u/s 153C - Unexplained investment being share capital and share premium - no incriminating material seized during search. CIT(A) held that three conditions...

  10. The final assessment order passed by the Assessing Officer u/s 147 read with Section 144C(13) for the Assessment Year 2016-17 is quashed as barred by limitation. Except...

  11. Validity of assessment passed u/s 153A pursuant to search and seizure - The High Court has observed and held that, the assessee’s assessment for the relevant year stood...

  12. Reopening of assessment u/s 147 - Tribunal was correct to hold that when reference was made to the TPO by AO for determination of arm’s length price in relation to the...

  13. Validity of reopening of assessment u/s 147 - by the time, assessment order for the assessment year 2004-05 was passed on 31.12.2010, six year period for reopening of...

  14. The ITAT held that the assessment years 2009-10, 2010-11 and 2011-12 were beyond the 10-year limitation period u/s 153C read with Explanation-1 to section 153A. Hence,...

  15. Assessment u/s 153A - Validity examined. Assessments cannot be framed without incriminating material found during search u/s 132. Completed assessments u/s 143(3) cannot...

 

Quick Updates:Latest Updates