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1 - 10 of 32 (0.33 seconds)The Coinage Act, 2011
Section 153C in The Income Tax Act, 1961 [Entire Act]
Section 132 in The Income Tax Act, 1961 [Entire Act]
Section 139 in The Income Tax Act, 1961 [Entire Act]
Section 80 in The Income Tax Act, 1961 [Entire Act]
Section 80AC in The Income Tax Act, 1961 [Entire Act]
Section 147 in The Income Tax Act, 1961 [Entire Act]
Section 153 in The Income Tax Act, 1961 [Entire Act]
Acit vs Smt. Pushpa Devi Jain [Alongwith Ita ... on 28 December, 2004
"14. From the above discussion and precedence, the scheme of assessment u/s.
153A of the Act in case of search, the AO shall issue notice to searched person
requiring him to furnish within such period as may be specified in the notice, the
return of income in respect of each assessment year falling within six
assessment years referred to in clause (b) of sub-section
sub section (1) of section 153A
and clause (b) postulates assessment or reassessment of the total income of six
years immediately preceding
preceding the assessment year relevant to the previous year
in which such search is conducted. The first proviso mandates that the AO shall
assess or reassess the total income in respect of each assessment year falling
within such six assessment years. The second second proviso postulates that the
assessment or reassessment, if any, relating to any assessment year falling
within the period of six assessment years referred to in sub- sub-section (1) is
pending on the date of initiation of the search u/s. 132 of the Act shall
shal abate. In
the present case before us, however, though the second proviso to sub-section
sub
(1) of section 153A would not apply in the first three years of this case, yet, as
far as the second three year period is concerned (which are pending before us),
the assessments were pending The proceedings in relation thereto abate. Now
the entire assessment in relation to the second phase of three years can be
made. The pending assessment in that case may be undertaken u/s. 153A of the
Act. The abatement of pending assessment is for the purpose of avoiding two
assessments for the same year i.e. one being regular assessment and the other
being search assessment u/s. 153A of the Act. In other words, these two
assessments merge into one assessment. It means that completed
completed assessments
stand on different footing from the pending assessments. Hence, in so far as
pending assessments are concerned, the jurisdiction to make original
assessment and assessment u/s. 153A of the Act merge into one and in that
ITA No.2232/Chny/20
/Chny/2024 (AY 2016-17)
M/s. JSR Infra Developers Pvt. Ltd.