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        Case ID :
        Income Tax

        The ITAT held that the assessment order dated 28.09.2021 passed...

        Assessment under s.143(3) read with s.254 held time-barred; s.153(3) first proviso limitation expired, assessment quashed (3)

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                The ITAT held that the assessment order dated 28.09.2021 passed by the AO under s.143(3) read with s.254 (or alternatively noted as r.w.s.254) was time-barred and invalid. The Tribunal found the fresh assessment mandate arose on 17.05.2019 and, applying the first proviso to s.153(3), required completion within 12 months from the end of the FY in which the tribunal order was rendered (limitation expiring 31.03.2021). Temporary timeline extensions related to COVID-19 could not revive an otherwise barred assessment. Consequently the s.143(3) assessment dated 28.09.2021 was quashed and the appeal allowed in favour of the assessee.
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