Time-Barred Section 153C Notice Renders Assessment Order Void: ITAT Chennai

KSJ Infrastructure Pvt Ltd Vs DCIT (ITAT Chennai) The Chennai ITAT ruled that the notice issued by the Assessing Officer (AO) under section 153C of the Income Tax Act for the subject assessment year was barred by limitation and void ab initio. This decision stemmed from a case where a search operation conducted on certain entities yielded incriminating material related to the assessee. However, since the notice was issued beyond the stipulated timeframe, it was deemed void. The ITAT emphasized that for proceedings under section 153C, the AO of the searched person must first record satisfaction...