Notice under S. 148 was served on the assessee on 30th March, 2014, the time-limit for reassessment as per S. 153(2) was available upto 31st March, 2015. Reassessment order was passed by AO purportedly on 30th March, 2015 incorporating the directions dt. 31st March, 2015 issued by the Addl. CIT under s. 144A of the Act. The Departmental Representative contended that it is a typographical error and the order may be treated passed on 31st March, 2015. The Tribunal held that the order passed by the Assessing Officer dt. 30th March, 2015 incorporating the directions dt. 31st March, 2015 issued by the Addl. CIT under S. 144A, it is obvious that the order was actually passed after 31st March, 2015 and, therefore, it was barred by limitation. (AY.2009-10)
Dy. CIT v. Clarion Technologies (P) Ltd. (2022) 216 TTJ 23 (UO) (Pune)(Trib)
S. 153 : Assessment-Reassessment-Limitation-Ante-dated order-Direction of Addl. CIT-AO in April, 2015 and signed by pre-dating it as 30th March, 2015-Assessment order was time barred and quashed. [S. 147, 148, 153(2)]