ITAT Hyderabad Quashes U/s 143(3) Assessment as Time-Barred; Sec 153 Exclusion Limited to Actual Time Lost

ACE Tyres (P) Ltd Vs DCIT (ITAT Hyderabad) Assessment U/s 143(3) Quashed as Time-Barred – Limitation u/s 153 & Exclusion Period Restricted to Actual Time Lost – ITAT Hyderabad The assessee, part of Exel Group, was subjected to search and assessment for A.Y. 2022-23 where addition of ₹2.04 crore was made based on alleged unaccounted transactions recorded in “FOCUS 5.5” software seized during search. The assessee challenged validity of assessment contending that the order dated 27.09.2024 was barred by limitation under s.153. ITAT analysed clause (xii) of Explanation-1 to s...