Supreme Court: Assessing Officer Misses Deadline u/s 142(2C), Loses Right to Make Tax Assessment.

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....Special audit U/s. 142(2C) - time limit for submission of Special Audit Report - once the period of limitation expires, the immunity against being subject to assessment sets in and the right to make assessment gets extinguished. Therefore in our considered opinion, the ratio laid down by the Hon’ble Supreme Court squarely applies to the instant case also. In the instant case on hand, the Ld. AO ought to have passed an order U/s. 142(2C) of the Act on or before 25/5/2019 ie., expiry of the first extension. - AT....