Section 153A Invoked for Wrong Year; Second Search Abates First – ITAT Quashes Search Assessment for AY 2020-21

Amolak Singh Bhatia Vs DCIT (ITAT Delhi) The Delhi Bench ‘E’ of the ITAT quashed the assessment framed under section 153A for AY 2020-21, holding that the proceedings were without jurisdiction and bad in law on multiple counts. The Tribunal noted that the first search on the assessee was initiated on 27.02.2020 and stood concluded with the last panchnama dated 01.03.2020. The prohibitory order passed under section 132(3) lapsed statutorily after 60 days (30.04.2020) and could not extend the search. Consequently, AY 2020-21 was the search year, for which assessment ought to have been framed...