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The ITAT held that the assessment years 2009-10, 2010-11 and 2011-12 were beyond the 10-year limitation period u/s 153C read with Explanation-1 to section 153A. Hence, the notice issued and assessments made u/s 153C for these years were barred by limitation, invalid, and quashed for want of valid jurisdiction. The consolidated satisfaction notes recorded by the AOs for multiple years were improper as separate notes were required year-wise. The additions made u/s 68 for the years 2009-10 to 2013-14 were unsustainable due to lack of jurisdiction and invalid, and hence quashed. The approval granted u/s 153D was treated as invalid and bad in law due to lack of proper application of mind and recording of satisfaction by the Addl. CIT. The addition of Rs. 60 lakh u/s 68 for 2009-10 was unjustified as no credit entry was found in the books. The addition of Rs. 1.25 crore u/s 68 for 2013-14 was deleted as it involved double taxation of amounts already offered under IDS 2016.
The ITAT held that the assessment years 2009-10, 2010-11 and 2011-12 were beyond the 10-year limitation period u/s 153C read with Explanation-1 to section 153A. Hence, the notice issued and assessments made u/s 153C for these years were barred by limitation, invalid, and quashed for want of valid jurisdiction. The consolidated satisfaction notes recorded by the AOs for multiple years were improper as separate notes were required year-wise. The additions made u/s 68 for the years 2009-10 to 2013-14 were unsustainable due to lack of jurisdiction and invalid, and hence quashed. The approval granted u/s 153D was treated as invalid and bad in law due to lack of proper application of mind and recording of satisfaction by the Addl. CIT. The addition of Rs. 60 lakh u/s 68 for 2009-10 was unjustified as no credit entry was found in the books. The addition of Rs. 1.25 crore u/s 68 for 2013-14 was deleted as it involved double taxation of amounts already offered under IDS 2016.
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