Held that the notice under S. 148 was issued to the assessee on 30th March, 2021 and no reference was made under S. 92CA(1), the time-limit for completing the assessment under s. 147 was available upto 31st March, 2022 as per ss. 153(2) and 153(4) being not applicable. The final assessment order passed by the AO under s. 144 r/w s. 144C, dt. 12th Jan., 2023 is barred by limitation. (AY. 2017-18)
Syed Gulam Mohiuddin v. ITO (IT) (2024) 230 TTJ 956 / 38 NYPTTJ 716/ 163 taxmann.com 234 (Hyd)(Trib)
S. 153 : Assessment-Reassessment-Limitation-Non-resident-The assessment was made as per the procedure laid down in S. 144C-No reference was made under S. 92CA(1)-Time-limit for completing the assessment under S. 147 was available upto 31st March, 2022-The final assessment order passed by the AO under s. 144 r/w s. 144C, dt. 12th Jan., 2023-Barred by limitation. [S.92CA, 144, 144C,147, 148 153(2)]