Chintankumar Rameshbhai Patel v. Dy. CIT (2025) 210 ITD 290 (Rajkot) (Trib.)

S. 153B: Assessment-Search-Time limit-Limitation to pass the assessment order expired on 31.12.2020 [S. 69B, 132,153A, 153C]

A search action u/s 132 was carried out at the residential premises of ‘D’. Pursuant to the same, notice u/s 153C was issued to the Assessee. Assessment proceedings were carried out and the AO passed an assessment order u/s 153C r.w.s. 143(3) on 21.04.2021, making addition of certain amounts u/s 69B. It was held that as per the first proviso to S. 153B, the assessment order ought to be passed by 31.12.2020 for AY 2016-17, and the delay in passing the said assessment order of 111 days was barred by limitation. (AY.2016-17,  2017-18)

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