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ITAT held that on remand after an order under s.254, the A.O. could only pass a fresh assessment pursuant to s.153(2A) within one year from the end of the financial year in which the s.254 order was made; where the Tribunal's s.254 order dated 31/08/2012 thus required finalisation by 31/03/2014, the impugned final assessment issued thereafter was time-barred. Applying the statutory construction that "received" equates to "having knowledge," the Tribunal set aside the belated assessment as invalid for breach of limitation. The taxpayer's appeal was therefore partly allowed and the assessment annulled to the extent time-barred.
ITAT held that on remand after an order under s.254, the A.O. could only pass a fresh assessment pursuant to s.153(2A) within one year from the end of the financial year in which the s.254 order was made; where the Tribunal's s.254 order dated 31/08/2012 thus required finalisation by 31/03/2014, the impugned final assessment issued thereafter was time-barred. Applying the statutory construction that "received" equates to "having knowledge," the Tribunal set aside the belated assessment as invalid for breach of limitation. The taxpayer's appeal was therefore partly allowed and the assessment annulled to the extent time-barred.
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