A search and seizure was conducted on the premises on the assessee on 28.5.2014 but the order of assessment was passed only in 2017. Having failed to type the DNCR on the assessment order and also since the issue of limitation is covered in favour of the assessee by the jurisdictional high court holding that in the absence of dispatch date showing the issue of order of assessment the order is beyond limitation and the burden is on the revenue to show the same.(AY. 2009-2010 to 2015-2016)
Sujata Panda v. ACIT (2022) 220 TTJ 899 (Cuttack) (Trib)
S. 153B : Assessment-Search-Time limit-DNCR not handwritten in assessment order-Order was not passed within limitation period-Order liable to be quashed as beyond limitation. [S. 132, 153D]