Validity of Assessment u/s 153C - The period of six years would ...

Case Laws Income Tax

May 20, 2024

Validity of Assessment u/s 153C - The period of six years would have to be reckoned with respect to the date of recording of satisfaction note, not the date of search. The court concluded that assessments made for AY 2012-13 u/s 144 r.w.s. 142(1), consequent to the satisfaction note recorded on 18.11.2013 (AY 2014-15), ought to have been made u/s 153C. Since the provisions of Section 153C were not invoked, the assessment made u/s 144 r.w.s. 142(1) is treated as void ab initio.

View Source

← Previous Next →

Validity of Assessment u/s 153C - The period of six years would ...

Case Laws Income Tax

May 20, 2024

You may also like:

Notice issued for reopening assessment u/s 147 was beyond the limitation period stipulated in Section 149(1). The High Court, following Ojjus Medicare Pvt. Limited,...

The Income Tax Appellate Tribunal examined the validity of assessments made u/s 153C, considering the gap between the satisfaction note recorded by the Assessing Officer...

Assessment proceedings u/s 153C - The period of limitation and deemed date for possession of seized documents were discussed. It was held that the date of recording...

Assessment order passed u/s 143(3) by issuing notice u/s 143(2) quashed as invalid. Assessment for relevant assessment year should have been carried out by issuing...

Section 153C provisions are inapplicable as notice was issued to 'other person' under this section. Computation of six-year block period preceding assessment year...

The assessment u/s 153C mandates the recording of satisfaction by the Assessing Officer (AO) upon discovery of material likely to "have a bearing on the determination of...

Initiation of proceedings as barred by limitation - proviso to section 153C - satisfaction to initiate proceedings u/s 153C was arrived on 15.09.2014 and the six...

The Appellate Tribunal held that the assessment orders issued u/s 153C for the assessment years 2011-12 and 2012-13 were beyond the jurisdiction of the Assessing Officer...

Validity of assessment u/s 153C - There is no prohibition in the Act that a combined satisfaction-note should not be recorded. Moreover, the satisfaction- note, is...

Assessment u/s 153C - Profit estimation on money received for new construction and redevelopment projects - extrapolation of income for the search period. The assessee...

The assessment years beyond six years but not exceeding ten years can be reopened u/s 153A only if the Assessing Officer possesses evidence depicting escapement of...

Section 153C applies equally to all non-searched entities, without creating a separate regime where the AO of the searched and non-searched entity are the same. The...

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,...

Validity of assessment u/s 153C - Period of limitation - Assessment of income of any other person in search proceedings - The proviso in Section 153C(1) includes not...

The assessment year in question falls beyond the stipulated six assessment years and four relevant assessment years, rendering the notice issued by the Assessing Officer...

Quick Updates: