Tribunal condoned the delay of 492 days in filing the appeal due to bonfide mistake of the Accountant. Information collected during course of search from another person, all search assessments were required to be made in case of assessee under sections 153A or 153C, but not under section 147. Reassessment was quashed. Reassessment completed without communicating reasons recorded to assessee, when specifically requested was held to be unsustainable and quashed. (AY. 2009-10 to 2011-12)
Samanthapudi Lavanya (Smt.) v. ACIT (2021) 189 ITD 401 (Vishakha)(Trib.)
S. 147 : Reassessment-Search and seizure-Search assessment was required to be made under section 153A or 153C-Reassessment was quashed-Reassessment without communication of reasons recorded when request was made-Reassessment is bad in law-Delay of 492 days in filing of appeal due to mistake of accountant was condoned. [S. 132(4), 148, 153A, 153C, 254(1)]