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The ITAT held that the assessment for AY 2008-09 initiated u/s 153A was beyond the 10-year limitation period prescribed, rendering the assessment order invalid. However, regarding the addition of share capital and share premium u/s 153A, the ITAT upheld the CIT(A)'s finding of incriminating material, validating the assessment order, relying on the Goldstone Cements Ltd. case. The appeals were partly allowed and partly dismissed.
The ITAT held that the assessment for AY 2008-09 initiated u/s 153A was beyond the 10-year limitation period prescribed, rendering the assessment order invalid. However, regarding the addition of share capital and share premium u/s 153A, the ITAT upheld the CIT(A)'s finding of incriminating material, validating the assessment order, relying on the Goldstone Cements Ltd. case. The appeals were partly allowed and partly dismissed.
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