Notice u/s 153C beyond six Assessment Year from date of recording of satisfaction note is without jurisdiction

ACIT Vs Opal Buildwell P. Ltd. (ITAT Delhi) ITAT Delhi held that issuance of notice u/s 153C of the Income Tax beyond six Assessment Year immediately preceding the Assessment year from the date of recording of satisfaction note/ handling over of relevant material is not in accordance with law. Facts- The assessee filed its return of income for A.Y. 2010-11 declaring income of Rs. 2,81,421/- which was processed u/s. 143(1) of the Act. Subsequently, the assessment has been reopened u/s. 153C of the Act on the allegation that certain documents/papers belonging to the appellant were found during t...