Dismissing the appeal of the revenue the High Court held that the Tribunal is justified in holding that Assessing Officer could not have initiated and passed an assessment order under section 153C for relevant assessment year as same was beyond period of six years from end of financial year in which satisfaction note was recorded by Assessing Officer. Satisfaction for initiation of proceedings under section 153C was recorded by Assessing officer on 02-02-2015. Followed IT v. RRJ Securities Ltd (2016) 380 ITR 612 (Delhi) (HC). (AY. 2007-08)
PCIT v. Raj Buildworth (P.) Ltd. (2020) 113 taxmann.com 600 (Delhi) (HC) Editorial: SLP of revenue is dismissed PCIT v. Raj Buildworth (P.) Ltd (2020) 269 Taxman 383 (SC)
S. 153C : Assessment-Income of any other person-Initiation of assessment proceedings beyond period of six years from end of financial year in which satisfaction note was recorded by Assessing Officer is held to be not valid. [S. 132]