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The assessment year in question falls beyond the stipulated six assessment years and four relevant assessment years, rendering the notice issued by the Assessing Officer u/s 153C of the Act, dated 31.12.2021, and the consequent assessment order passed u/s 143(3) read with Section 153C, dated 31.03.2022, barred by limitation. Following the decision of the Honorable Supreme Court in the case of CIT vs Jasjit Singh, for the purpose of the proviso to Section 153C(1) of the Act, in the case of such other person, the reference to the date of initiation of search u/s 132 of the Act in the second proviso to Section 153A(1) shall be construed as the date of receiving the books of accounts or other documents by the Assessing Officer having jurisdiction over such other person, which is considered as 31.12.2021 in the present case. Consequently, the assessment order passed by the Assessing Officer u/s 143(3) read with Section 153C, dated 31.03.2022, is quashed, and the decision is in favor of the assessee.
The assessment year in question falls beyond the stipulated six assessment years and four relevant assessment years, rendering the notice issued by the Assessing Officer u/s 153C of the Act, dated 31.12.2021, and the consequent assessment order passed u/s 143(3) read with Section 153C, dated 31.03.2022, barred by limitation. Following the decision of the Honorable Supreme Court in the case of CIT vs Jasjit Singh, for the purpose of the proviso to Section 153C(1) of the Act, in the case of such other person, the reference to the date of initiation of search u/s 132 of the Act in the second proviso to Section 153A(1) shall be construed as the date of receiving the books of accounts or other documents by the Assessing Officer having jurisdiction over such other person, which is considered as 31.12.2021 in the present case. Consequently, the assessment order passed by the Assessing Officer u/s 143(3) read with Section 153C, dated 31.03.2022, is quashed, and the decision is in favor of the assessee.
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