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HC held the impugned notice dated 06.11.2020 to be barred by limitation and quashed it, ruling for the respondent-assessee. The court construed s.153(7) (as amended by the Finance Act, 2016) together with s.153(9), and, invoking the legislative Memorandum to the Finance Act, concluded the extended time-limit for cases pending on 01.06.2016 expired on 31.03.2017; consequently the assessment pursuant to the Tribunal's directions was required to be completed by that date. The Revenue's reliance on s.153(3)(ii) to give effect to the Tribunal's direction at any time was rejected as untenable. Decision therefore in favour of the assessee.
HC held the impugned notice dated 06.11.2020 to be barred by limitation and quashed it, ruling for the respondent-assessee. The court construed s.153(7) (as amended by the Finance Act, 2016) together with s.153(9), and, invoking the legislative Memorandum to the Finance Act, concluded the extended time-limit for cases pending on 01.06.2016 expired on 31.03.2017; consequently the assessment pursuant to the Tribunal's directions was required to be completed by that date. The Revenue's reliance on s.153(3)(ii) to give effect to the Tribunal's direction at any time was rejected as untenable. Decision therefore in favour of the assessee.
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