2 Years time limit u/s. 153B applies only to original order and to orders passed after remand

Surendra Kumar Jain Vs PCIT (Delhi High Court)

The general provision of two years, in the opinion of the Court, has been provided with one important objective i.e. to cater to a specific situation where upon search and seizure operation, if new material is found, already completed assessments are revisited. Had Parliament not prescribed such a specific period of limitation, possibly, the assessee’s concern would have successfully urged that search and seizure proceedings would be confined only to the concerne

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