assessment u/s 153C of the Act, as specified u/s 153B of the Act and hence the
assessment order is bad and illegal being ... assessment u/s 153C of the Act, as specified u/s 153B of the Act and hence the
assessment order is bad and illegal being
order is passed beyond the
period of limitation as prescribed under section 153B of the Act.
Therefore, the assessment may please be quashed.
2. That ... assessee invited our attention to the provisions of section 153B
providing time limit for making assessment for search & seizure cases.
The section 153B
assessment u/s 153C of the Act, as specified u/s 153B of the Act and hence the
assessment order is bad and illegal being ... assessment u/s 153C of the Act, as specified u/s 153B of the Act and hence the
assessment order is bad and illegal being
Court held that the
exclusion as provided under Explanation (ix) to Section 153B of the
Act is applicable only if a reference for exchange ... supra) held that the exclusion as provided under Explanation (ix) to
Section 153B (which was numbered as Clause (viii) at the material
time) is applicable
Court held that the
exclusion as provided under Explanation (ix) to Section 153B of the
Act is applicable only if a reference for exchange ... supra) held that the exclusion as provided under Explanation (ix) to
Section 153B (which was numbered as Clause (viii) at the material
time) is applicable
panchnama
was drawn in relation to the assessee.
4. As per section 153B(2)(a) of the Act, the authorization referred to in section
153B ... financial year 2019-20, i.e., 31.03.2021.
6. As per section 153B(1) of the Act, the time limit for framing assessments in
cases where
impugned assessment as being completed within the time limit
prescribed under Section 153B read with Section 153A of the Income-tax
Act, 1961, without appreciating ... said date; accordingly, the limitation for completion of
assessment under Section 153B , after considering the extensions
permitted under TOLA, expired on 30.09.2021, rendering the assessment
impugned assessment as being completed within the time limit
prescribed under Section 153B read with Section 153A of the Income-tax
Act, 1961, without appreciating ... said date; accordingly, the limitation for completion of
assessment under Section 153B , after considering the extensions
permitted under TOLA, expired on 30.09.2021, rendering the assessment
valid approval
as mandated u/s. 153D as per Section 153B(1)(b) , the alleged
search assessment u/s. 143(3) r.w.s. 153A ... proper procedure as mandated by law
u/s153D, 153A & 153B(1)(b); consequential search assessment
made would be invalid and is liable
valid approval
as mandated u/s. 153D as per Section 153B(1)(b) , the alleged
search assessment u/s. 143(3) r.w.s. 153A ... proper procedure as mandated by law
u/s153D, 153A & 153B(1)(b); consequential search assessment
made would be invalid and is liable