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Commissioner Of Income Tax vs Shri K.M.Ganesan on 30 November, 2009

30. The ld. DR for the revenue has failed to bring to our notice any other decision to the contrary and in view of the ratio laid down by the Hon'ble Madras High Court in the case of CIT Vs K.M.Ganeshan (supra), we hold that the order passed under section 158BC read with S e c t i o n 1 5 8 B D o f t h e A c t i s b e yo n d t h e p e r i o d o f l i m i t a t i o n , a s t h e first notice under section 158BC(a) was issued on 21.06.1999 and the notice issued under section 158BC(a) read with section 158BD of the Act on 03.10.2000 was in line with the earlier proceedings initiated and hence, the assessment had to be completed within a period of two years from the end of the month of date of issue of last authorization for search under section 132 of the Act. The order passed on 31.10.2002 is beyond the period of limitation and hence the same is invalid. C o n s e q u e n t l y, t h e a d d i t i o n s m a d e v i d e t h e s a i d o r d e r p a s s e d under section 158BC(a) read with section 158BD of the Act do not stand and the same are hereby deleted.
Madras High Court Cites 5 - Cited by 4 - K R Pandian - Full Document
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