Section 153A Invoked for Wrong Year; Second Search Abates First – ITAT Quashes Search Assessment for AY 2020-21

Re: Assessment Order was non est as it was issued without mentioning DIN on the body of the Assessment Order and was informed via separate intimation letter. WITHOUT PREJUDICE, ASSUMING THE LIMITATION TO FRAMED ASSESSMENT ENDS ON 31.03.2022, THE ASSESSMENT ORDER IS STILL TIME BARRED9. This again is an infructuous ground as section 153B mandates that the assessment order should be passed within the time limit. Hence, the search assessment year in the given case would be only AY 2020-21. The relevance is the new incriminating materials found in the second search proceedings that are the loose papers found in the Almira.