3D Tradex P.Ltd vs ADIT, CPC, Bengaluru and ACIT, Circle-1(1)(1) Meerut, U.P
Parties Involved
Facts Summary
The case involves six appeals by the assessee, 3D Tradex P.Ltd, for the assessment years 2010-11 to 2015-16 and one appeal by the Revenue for the assessment year 2010-11. The appeals arise from the consolidated order dated 30.06.2022 of the Commissioner of Income Tax (Appeals)-28, New Delhi, passed under s. 250(6) of the Income Tax Act, 1961. The assessee challenges the assumption of jurisdiction under s. 153C of the Act, arguing that the limitation period for assessment has expired. The assessee contends that the 'Satisfaction Note' prepared by the Assessing Officer (AO) is vague and non-descript, failing to identify the undisclosed income for the relevant assessment years. The Revenue, on the other hand, argues that the limitation period should be reckoned from the date of the 'Satisfaction Note', which falls within the ten-year limitation period.…
Decision in favour of
Assessee
Legal Issues
- 1. Whether the assessment for AY 2010-11 & AY 2011-12 is barred by limitation under s. 153C of the Act.
- 2. Whether the 'Satisfaction Note' is vague and non-descript, making the assessment under s. 153C unfounded in law.
Judgment Outcome
Decided in favour of Assessee.
Precedents Relied Upon
8 precedents cited in this judgement.
Similar Judgements
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