Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
ITAT allowed the assessee's appeal and set aside the impugned assessment order as barred by limitation. The Tribunal held that after DRP issued directions u/s 144C(5) on 22/04/2022 and the TPO gave effect on 20/05/2022, the assessing officer was mandated by s.144C(13) to complete assessment within one month from the end of that month; the assessment dated 28/06/2022 exceeded the statutory timeline. Reliance was placed on precedent establishing the mandatory nature of the timeline under s.144C(13), such that failure to complete assessment within the prescribed period renders the proceedings time-barred. The rectification order did not cure the limitation defect.
ITAT allowed the assessee's appeal and set aside the impugned assessment order as barred by limitation. The Tribunal held that after DRP issued directions u/s 144C(5) on 22/04/2022 and the TPO gave effect on 20/05/2022, the assessing officer was mandated by s.144C(13) to complete assessment within one month from the end of that month; the assessment dated 28/06/2022 exceeded the statutory timeline. Reliance was placed on precedent establishing the mandatory nature of the timeline under s.144C(13), such that failure to complete assessment within the prescribed period renders the proceedings time-barred. The rectification order did not cure the limitation defect.
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