Limitation under Section 153: period lost during handover of books is excluded; assessment beyond extended deadline is time-barred.
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....Time lost by the assessing officer during search-related handover of books of account is excluded from the 180-day limitation under the relevant provision, but only to the extent that the handover period is included in the original limitation period; consequently the excluded period (1/4/2023-22/8/2023, 144 days) extends the assessment deadline to 22/8/2024. The assessment order dated 27/9/2024 was therefore beyond the extended limitation and is time barred, and the assessee's appeal is allowed.....
TaxTMI