2017 (8) TMI 279

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....ax (Appeals), Alwar dated July 20, 2015, May 17, 2015 and July 8, 2015 for the assessment years 2003-04, 2004-05, 2006-07, 2007-08, 2005-06, 2006-07, 2006-07, 2006-07 and 2006-07, 2007-08 and 2008-09 respectively. For the sake of convenience and brevity of the case, these appeals are being disposed of through a common order. 2. During the course of hearing is observed that in all these appeals of the assessees the learned authorised representative of the assessees prayed for the submission of the following additional ground : "In the facts and circumstances of the case and in law the assessment order passed is barred by limitation in terms of the time limit provided under section 153B. This assessment order passed deserves to be....

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.... 21-03-2006 (Belated return (PB-13) 31-3-2007 No order under section 143(3) 2. Rani Yogita 2006-07 31-7-2006 31-07-2007 (Belated return (PB) 19 31-7-2008 No order under section 143(3)     2007-08 31-7-2007 6-08-2007 (Belated return PB 21) 31-8-2008 No order under section 143(3) 3. Kulwant Rai 2005-06 31-7-2005 2-02-2006 (Belated return (PB) (19) 28-2-2007 No order under section 143(3)     2006-07 31-7-2006 31-07-2006 (Belated return (PB) (16) 31-7-2008 No order under section 143(3) 4. Shakuntala Devi 2006-07 31-7-2006 1-8-2007 (Belated return (PB-10) 31-8-2008 No order under section 143(3) 5. M/s Anil Agarwal and Sons HUF ....

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....of two years from the end of the financial year in which the last of the authorisation for search under section 132 or for requisition under section 132A was executed. (b) in respect of the assessment year relevant to the previous year in which search is conducted under section 132 or requisition is made under section 132A within a period of two years from the end of the financial year in which the last of the authorisation for search under section 132 or the requisition under section 132A was executed: Provided that in case of other person referred to in section 153C, the period of limitation for making the assessment or reassessment shall be the period as referred to in clause (a) or clause (b) of this sub- section or on....

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....e Assessing Officer of these assessees on April 1, 2011. Thus in terms of second proviso to section 153B the time limit for passing order under section 153C would be as under : (i) Twenty-one months from the end of the financial year in which the last of the authorisation for search under section 132 or the requisition under section 132A was executed, which is as under : Particulars Date Date of search 17-9-2008 End of the financial year in which search was executed 31-3-2009 Add 21 months 31-12-2010 (ii) Nine months from the end of the financial year in which books of account or documents or assets seized or requisitioned are handed over under section 153C to the Assessing Officer having jurisdiction over such....