Dismissing the petitions the Court held that as the information had been received only on July 28, 2020, which was beyond a period of one year, the extended period of one year was available to the Revenue. The assessments had been completed on December 31, 2019, and hence, were within time. Block comprises assessment years immediately preceding assessment year relevant to previous year in which search conducted, inclusion of Assessment years found to be in Order. Compliance with requirements of recording of satisfaction is mandatory. As regards the validity of search, the assessee was granted liberty to approach the first appellate authority by way of statutory appeals. The assessee was permitted to raise all grounds, barring those of limitation and challenge to the validity of the satisfaction note, that have been decided adverse to it. (AY.2010-11 to 2014-15)
R. K. M. Powergen Pvt. Ltd. v. Asst. CIT (2023)459 ITR 792/146 taxmann.com 68 / 334 CTR 68(Mad)(HC) R. K. Powergen Pvt. Ltd. v. Asst. CIT (2023)459 ITR 792/146 taxmann.com 68 (Mad)(HC)
S. 153C : Assessment-Income of any other person-Search-Limitation-Request for information from competent Authority-Further period of one year or till such time receipt of information by Assessing Officer-Completion of assessment within time-Block period-Block comprises assessment years immediately preceding assessment year relevant to previous year in which search conducted-Inclusion of Assessment years found to be in Order-Satisfaction note by Assessing Officer of searched person-Compliance with requirements of recording of satisfaction is mandatory-Warrant-Validity of search-Liberty to approach first Appellate authority. [S. 132, 153A, Art. 226]