The time frame for framing an assessment in terms of section 153C has been fixed bearing in mind the practical consideration that assimilation of materials relating to third person to whom those assessment relates, is bound to take some time . More often than not , it is only upon competition of the primary assessment ( Under section 153A)) that the Assessing Officer eve comes to a reasoned conclusion as to whether proceedings are to be initiated against such a person or not . Seized material was handed over on 27 -8 2019 hence the order is not barred by limitation Writ petition was dismissed- Directed to pursue alternative remedy (AY.2015-2016)
Savithri Naidu v. ACIT (2023) 330 CTR 200 / 212 DTR 462 (Mad)( HC)
S. 153A: Assessment – Search or requisition- Order was not barred by limitation – Seized material was handed on 27 -8 -2019 – Writ petition was dismissed- Directed to pursue alternative remedy . [S.153C(2) Art , 226 ]