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ITAT quashed assessment order made under section 143(3) for AY 2021-22, declaring it void ab initio. The assessment, based on materials from search operations conducted on Hans Group, should have been processed under section 153C rather than regular assessment under 143(3). Following first proviso to section 153C, AY 2023-24 being search year, assessments for six prior years (2017-18 to 2022-23) required completion under 153C. Despite recording satisfaction note under 153C, AO's completion of assessment under 143(3) was held legally impermissible. Tribunal relied on similar precedent from Mukul Rani Thakur case involving identical Hans Group search circumstances.
ITAT quashed assessment order made under section 143(3) for AY 2021-22, declaring it void ab initio. The assessment, based on materials from search operations conducted on Hans Group, should have been processed under section 153C rather than regular assessment under 143(3). Following first proviso to section 153C, AY 2023-24 being search year, assessments for six prior years (2017-18 to 2022-23) required completion under 153C. Despite recording satisfaction note under 153C, AO's completion of assessment under 143(3) was held legally impermissible. Tribunal relied on similar precedent from Mukul Rani Thakur case involving identical Hans Group search circumstances.
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