Esha Securities P. Ltd. v. Dy. CIT (2024)114 ITR 24 (SN)(Delhi)(Trib)

S. 153C : Assessment-Income of any other person-Search–Six assessment years to be reckoned from date of recording of satisfaction-AY. 2004-05 is beyond six years-Order is quashed and set aside. [S. 132]

Held that  the date of search would become the date of recording satisfaction, i. e., November 23, 2010. The assessment year 2004-05 would fall beyond the period of six assessment years as reckoned with reference to the date of recording of satisfaction by the Assessing Officer of the searched person. The assessment order is  without jurisdiction.(AY.2004-05, 2005-06)

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