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HC held that the Assessment Order u/s 153C was not time-barred due to COVID-19 related limitation extensions. The statutory period for passing the order would have expired on 31.03.2023, but governmental disruptions and subsequent legislative measures like Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 and TOLA 2021 effectively extended the limitation period. The court ruled that the assessment order was within jurisdiction, overruling the petitioner's objection. The respondent shall apply preponderance of probability standard and make efforts to produce the director for cross-examination within six months.
HC held that the Assessment Order u/s 153C was not time-barred due to COVID-19 related limitation extensions. The statutory period for passing the order would have expired on 31.03.2023, but governmental disruptions and subsequent legislative measures like Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 and TOLA 2021 effectively extended the limitation period. The court ruled that the assessment order was within jurisdiction, overruling the petitioner's objection. The respondent shall apply preponderance of probability standard and make efforts to produce the director for cross-examination within six months.
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