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The HC held that the final assessment order pursuant to the ITAT's direction dated 20.07.2012 for AY 2007-08 was not passed within the prescribed limitation period. Consequently, any further proceedings before the AO are time-barred. The Revenue's failure to file a counter affidavit and the untraceability of relevant files reinforced the conclusion that the assessment process was invalid. The Court directed acceptance of the petitioner's return and ordered the refund of the claimed amount along with any further payments made, including interest as per law. This decision aligns with established precedent on limitation in assessment proceedings.
The HC held that the final assessment order pursuant to the ITAT's direction dated 20.07.2012 for AY 2007-08 was not passed within the prescribed limitation period. Consequently, any further proceedings before the AO are time-barred. The Revenue's failure to file a counter affidavit and the untraceability of relevant files reinforced the conclusion that the assessment process was invalid. The Court directed acceptance of the petitioner's return and ordered the refund of the claimed amount along with any further payments made, including interest as per law. This decision aligns with established precedent on limitation in assessment proceedings.
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