https://www.taxtmi.com/caselaws?id=770605 The ITAT Delhi held that an assessment order passed under section 153C read with section 143(3) for assessment year 2012-13 was barred by limitation. The AO assumed jurisdiction on 29.06.2021 when incriminating material was handed over, making 2021-22 the year of search. Under section 153C(1), assessments can only be opened for six assessment years immediately preceding the relevant assessment year, or ten years under the Finance Act 2017 amendment. Since AY 2012-13 fell beyond both the six-year and ten-year periods, the assessment was time-barred. The tribunal followed the coordinate bench decision in MG Fincap and Delhi HC ruling in Pr. CIT vs. Ojjus Medicare, deciding in favor of the assessee. en-us Wed, 07 May 2025 00:00:00 +0530 Wed, 14 May 2025 07:48:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770605 The ITAT Delhi held that an assessment order passed under section 153C read with section 143(3) for assessment year 2012-13 was barred by limitation. The AO assumed jurisdiction on 29.06.2021 when incriminating material was handed over, making 2021-22 the year of search. Under section 153C(1), assessments can only be opened for six assessment years immediately preceding the relevant assessment year, or ten years under the Finance Act 2017 amendment. Since AY 2012-13 fell beyond both the six-year and ten-year periods, the assessment was time-barred. The tribunal followed the coordinate bench decision in MG Fincap and Delhi HC ruling in Pr. CIT vs. Ojjus Medicare, deciding in favor of the assessee. Case-Laws Income Tax Wed, 07 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770605