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| The Tax Publishers2020 TaxPub(DT) 1020 (SC) : (2020) 269 TAXMAN 0383 INCOME TAX ACT, 1961
Section 261 Section 153C
Where the department preferred SLP to appeal against the judgment of High Court held that in instant case AO of search party and assessee was the same in such a factual matrix, AO could not have initiated and passed an assessment order under section 153C to relevant assessment year, as it was beyond period of six years from end of financial year in which satisfaction note was recorded by AO, the Supreme Court dismissed the SLP on the ground of delay, leaving all the questions of law open.
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Appeal (Supreme Court) - Special leave petition - Search and seizure - Validity--Search proceedings initaited after expiry of six years from relevant financial year
Department preferred SLP to appeal against the judgment of Delhi High Court in Pr. CIT v. Raj Buildworth (P.) Ltd. [ITA No. 1149 of 2018, dt. 23-10-2018] : 2020 TaxPub(DT) 1028 (Del-HC), whereby the High Court held that in instant case AO of search party and assessee was the same in such a factual matrix, AO could not have initiated and passed an assessment order under section 153C to relevant assessment year, as it was beyond period of six years from end of financial year in which satisfaction note was recorded by AO.Held: The Supreme Court dismissed the SLP on the ground of delay, leaving all the questions of law open.
REFERRED :
FAVOUR : SLP dismissed.
A.Y. :
IN THE SUPREME COURT OF INDIA
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