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RU
Karnataka HC Upholds Section 153C Notices Within Extended 10-Year Assessment Block
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taxguruin
The original notices dated 05.08.2019 for Assessment Years 2011-12 to 2017-18 had been withdrawn, following which fresh notices were issued.
The respondent supplied the satisfaction note recorded by the Assessing Officer of the searched person on 31.03.2018 and the satisfaction note recorded by the jurisdictional Assessing Officer on 23.10.2019.
It was further argued that no statutory time limit existed for recording satisfaction by the jurisdictional Assessing Officer.
Accordingly, even taking 23.10.2019 as the relevant date for recording satisfaction, Assessment Years 2009-10 to 2018-19 fell within the permissible ten-year block and the notices issued for Assessment Years 2009-10 to 2014-15 were valid.
By virtue of Finance Act, 2017 the block period for search assessment stood extended to ten assessments years on account of the introduction of the concept of “relevant assessment year or years”.