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| The Tax Publishers2020 TaxPub(DT) 1028 (Del-HC) INCOME TAX ACT, 1961
Section 153C
AO could not have initiated and passed an assessment order under section 153C for relevant assessment year, as it was beyond period of six years from end of financial year in which satisfaction note was recorded by AO.
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Search and seizure - Validity - Search proceedings initiated after expiry of six years from relevant Financial year -
Issue was as regards validity of proceedings initiated under section 153C beyond a period of six years from end of financial year preceding date on which satisfaction was recorded. Held: 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 for relevant assessment year, as it was beyond period of six years from end of financial year in which satisfaction note was recorded by AO.
REFERRED :
FAVOUR : In assessee's favour
A.Y. :
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