On writ to quash the assessment the assessee has raised objections to the assumption of jurisdiction on August 13, 2022. The Court held that objection was rejected by a written order dated September 28, 2022. The satisfaction note was appended thereto. The assessee slept over the matter for more than one year. Merely because, the assessment proceedings may have been transferred in the meanwhile, that did not explain the laches that otherwise existed. Court held that the assessee had acted with delay. Since the assessment proceedings were about to become time barred and the assessee had acted late, the discretionary jurisdiction under article 226 of the Constitution of India is dismissed. (AY. 2011-12)
Ranjana Agarwal v. ACIT (2025) 478 ITR 463 (All)(HC)
S. 153C : Assessment-Income of any other person-Search-Objection to jurisdiction-Delay in filing-Writ petition to quash the assessment order is dismissed. [S. 132, Art.226]
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