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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.
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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