Proceedings u/s 158BD raised after gap of 3 years, even after completion of block assessment, not maintainable – ITAT

Brief of the Case:  ITAT Delhi held In the case of ACIT vs. Raj Kumar Jalan that in view of the proposition laid down by the Honble Delhi high Court in the case of CIT Vs. Bharat Bhusan Jain and others in ITA No.648/09 and 669/2009 etc order dated 08.01.2015, we are of the view that the period of above three years cannot be considered as “immediate” or “immediately proximate” in point of time to the completion of the block assessment u/s 158BD. The assessment itself is bad in law. Thus application under Rule 27 of the ITAT Rules is allowed. Facts of the Case:   The AO initiated proc...