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 ]

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)