2022 (12) TMI 1530

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..... , the Assessing Officer has not taken up the assessment proceedings within a reasonable time and therefore, the entire proceedings are vitiated by reason of delay As decided by HC [ 2022 (6) TMI 848 - MADRAS HIGH COURT] provisions of Sections 144C and 153 are not mutually exclusive, but are rather mutually inclusive. The period of limitation prescribed u/s 153 (2A) or 153 (3) is applicable, when t .....

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..... hin 12 months, as the very purpose of extension is to ensure that orders are passed within the extended period, as otherwise the extension becomes meaningless. The outer time limit of 33 months in case of reference to TPO under Section 153, would not refer to draft order, but only to final order and hence, the entire proceedings would have to be concluded within the time limits prescribed, HELD TH .....

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