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The ITAT quashed the assessment order passed under section 143(3) dated 27/03/2015. The Tribunal held that since the satisfaction note for initiating proceedings under section 153C was recorded on 10/10/2024, the assessment year relevant to the search was AY 2015-16, with the preceding six years being AY 2009-10 to 2014-15. As the impugned AY 2013-14 fell within this block period, the assessment should have been completed under section 153C rather than section 143(3). Following the precedent established in Jasjit Singh (affirmed by Delhi HC), the ITAT allowed the assessee's appeal and quashed the improperly framed assessment.
The ITAT quashed the assessment order passed under section 143(3) dated 27/03/2015. The Tribunal held that since the satisfaction note for initiating proceedings under section 153C was recorded on 10/10/2024, the assessment year relevant to the search was AY 2015-16, with the preceding six years being AY 2009-10 to 2014-15. As the impugned AY 2013-14 fell within this block period, the assessment should have been completed under section 153C rather than section 143(3). Following the precedent established in Jasjit Singh (affirmed by Delhi HC), the ITAT allowed the assessee's appeal and quashed the improperly framed assessment.
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