Amit Kumar Alias Amit Sarraf v. UOI (2024)462 ITR 205 (Pat)(HC)

S. 153A: Assessment-Search-Limitation-Direction is issued to refund the entire seized cash with interest-Reassessment notice is quashed. [S. 132A, 132B (4), 147, 148, 153B, Art. 226]

Held, that there was no dispute as to the first and last requisitions having been made on June 6, 2017 in the assessment year 2018-19, corresponding to the financial year 2017-18, and the last date of the relevant assessment year in which the requisition was made would be March 31, 2018 and the period of limitation would expire on December 31, 2020. No assessment was initiated on or before that date under section 153A. The assessments were initiated that too under section 148 for the assessment years 2013-14 to 2018-19 on March 31, 2021, long after the assessment period had expired. Hence, a direction would issue to the Department to refund the entire seized cash with interest, as provided under section 132B(4).(AY.2013-14 to 2018-19)