Refund claim dismissed as time-barred under s.142(5); non-obstante clause read restrictively, merits not decided, self-assessment payments not mere de...
Assessee's project-completion revenue recognition upheld; income addition deleted under Guidance Note/AS-9 and percentage-completion rules as complian...
The HC held that notices issued under section 153C are time-barred and therefore invalid. Applying the governing limitation principle, the ten-year block for assessment is computed from the date on which the jurisdictional AO of the non-searched person received books, documents or assets seized from the jurisdictional AO of the searched person. On the facts, the relevant assessment years (AYs 2010-11 to 2015-16) fell outside the ten-year period as of the notice dates. Consequently, the petitions by the taxpayers were allowed and the impugned notices dated 31.08.2024 and 12.09.2024 issued under section 153C were quashed.
The HC held that notices issued under section 153C are time-barred and therefore invalid. Applying the governing limitation principle, the ten-year block for assessment is computed from the date on which the jurisdictional AO of the non-searched person received books, documents or assets seized from the jurisdictional AO of the searched person. On the facts, the relevant assessment years (AYs 2010-11 to 2015-16) fell outside the ten-year period as of the notice dates. Consequently, the petitions by the taxpayers were allowed and the impugned notices dated 31.08.2024 and 12.09.2024 issued under section 153C were quashed.
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