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ITA No. 701/Coch/2023 & CO No. 1/Coch/2024

Date: 9/25/2024

Parties Involved

appellantK.K. Mohandas
respondentACIT, Central Circle - 2

Facts Summary

The case involves an appeal by the Revenue against the National Faceless Appeal Centre, Delhi's order quashing the impugned assessment dated 29.03.2016 for the Assessment Year 2013-14. The Revenue argued that the Assessing Officer's assessment was within the time limit as the Assessing Officer was common between the searched party and the assessee. However, the Tribunal found that the Assessing Officer had recorded satisfaction under section 153C on 21.05.2013, relevant to AY 2014-15, and not for AY 2013-14. The Tribunal concluded that the impugned assessment was time-barred as it was framed beyond the statutory limitation under section 153B of the Act.

Decision in favour of

Partly Assessee / Partly Revenue

Legal Issues

  • 1. Whether the impugned assessment dated 29.03.2016 is time-barred?

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

2 precedents cited in this judgement.

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ITA No. 701/Coch/2023 & CO No. 1/Coch/2024 | 2024 | Opakhya