Held that, in the absence of any documentary evidence on record to show that the impugned assessment order under S. 153A of the Act purportedly passed on 30/12/2016 which was dispatched by the Department only on 07/01/2017 was in fact passed on 30/12/2016 before the expiry of the limitation period, the same is barred by limitation. (AY 2009-10 to AY 2015-16)
Sujata Panda v. ACIT (2022) 220 TTJ 899 / 220 DTR 185 (Ctk) (Trib.)
S. 153A : Assessment-Search or requisition-Assessment-Limitation-The JCIT granted the approval u/s. 153D on 30/12/2016 does not prove that the order has been passed on 30/12/2016 and hence the assessment order purported to have been passed on 30/12/2016 is barred by limitation and therefore quashed. [S. 153, 153D 153B]