Sri Sat Sahib Housing and Infrastructure Development company vs DCIT/ACIT
Parties Involved
Facts Summary
The assessee, Sri Sat Sahib Housing and Infrastructure Development company, is engaged in housing and infrastructure development. A search and seizure operation under section 132 of the Income-tax Act, 1961 was conducted on 14.09.2017 in the case of Dalal Group of cases. Documents pertaining to the assessee were found, and a satisfaction note was recorded by the Assessing Officer on 19.03.2020 for initiating proceedings under section 153C of the Act for Assessment Years 2008-09 to 2010-11. The assessee argued that the assessment proceedings for these years are time-barred as the deemed year of search is AY 2020-21, and the 10-year block calculation ends at AY 2011-12.…
Decision in favour of
Assessee
Legal Issues
- 1. Whether the proceedings under section 153C for Assessment Years 2008-09 to 2010-11 are illegal, bad in law, without jurisdiction, and barred by the limitation of time.
Judgment Outcome
Decided in favour of Assessee.
Precedents Relied Upon
5 precedents cited in this judgement.
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