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Assessment order passed u/s 143(3) by issuing notice u/s 143(2) quashed as invalid. Assessment for relevant assessment year should have been carried out by issuing notice u/s 153C in case of search. Six-year period for initiating proceedings u/s 153C reckoned from date of recording satisfaction regarding possession of seized documents. Additional grounds raised by assessee allowed.
Assessment order passed u/s 143(3) by issuing notice u/s 143(2) quashed as invalid. Assessment for relevant assessment year should have been carried out by issuing notice u/s 153C in case of search. Six-year period for initiating proceedings u/s 153C reckoned from date of recording satisfaction regarding possession of seized documents. Additional grounds raised by assessee allowed.
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