Bhavin Kishorebhai Zinzuwadia v. ACIT (2025) 303 Taxman 73 (Guj.)(HC)

S. 153C : Assessment-Income of any other person-Recording of satisfaction on 23-10-2019-First AY 2018-19, tenth AY 2009-10-Notices for AYs 2009-10 to 2014-15 not time-barred.[S. 153A, Art. 226]

Search on 10-03-2015 at Venus Infrastructure and Developers Pvt Ltd  group premises led to seizure of documents relating to the assessee. Satisfaction was recorded on 23-10-2019 by the jurisdictional AO. The assessee argued notices were time-barred. The Court held that with satisfaction recorded on 23-10-2019, the first AY was 2018-19 and the tenth AY 2009-10. Applying the extended 10-year limit under section 153C r.w.s. 153A (as amended by Finance Act, 2017) for escaped income exceeding Rs. 50 lakhs, the notices were within time. Petition dismissed. (S. 153C)

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