TMI BlogSearch Assessment: Limitation Period Bars Assessments, Additions Quashed for Lack of Jurisdiction and Invalid Approvals.The ITAT ruled that assessments for the years 2009-10, 2010-11, and 2011-12 were invalid due to being beyond the 10-year limitation period under section 153C, as per section 153A. Notices and assessments for these years were quashed for lack of jurisdiction. The consolidated satisfaction notes by the Assessing Officers were improper, requiring year-wise notes. Additions under section 68 for 2009-10 to 2013-14 were unsustainable and quashed. The approval under section 153D was invalid due to inadequate application of mind. An addition of Rs. 60 lakh for 2009-10 was unjustified, and Rs. 1.25 crore for 2013-14 was deleted due to double taxation. ..... X X X X Extracts X X X X X X X X Extracts X X X X
|