ITAT: Notices for 2011-12, 2012-13 Quashed; Reassessment Invalid Due to 6-Year Limit Breach and Lack of Direct Evidence.

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....The ITAT held that the period of limitation for issuing a notice u/s 153C is six years from the end of the financial year preceding the date of recording satisfaction. In this case, the satisfaction was recorded on 31.10.2018 for AY 2018-19, so AYs 2011-12 and 2012-13 were outside the 6-year limit. The notice for these years was deemed not maintainable and quashed. The satisfaction note by the AO lacked a direct correlation between the seized material and the relevant assessment years as required by section 153C. As the seized documents did not establish this link, the reasoning for reopening the assessment was deemed vague and invalid. Following the precedent set in CIT vs. Sinhgad Technical Education Society, the reassessment proceedings u/s 153C were quashed, and the assessee's appeals were allowed.....