Initiation of Section 153C Proceedings Beyond Six Years Impermissible: ITAT Ahmedabad

DCIT Vs Suraj Limited (ITAT Ahmedabad)

ITAT Ahmedabad held that AO had no jurisdiction to initiate proceedings u/s. 153C of the Income Tax Act beyond permissible period of six years from date of receipt of books/ documents by AO.

Facts- A search u/s. 132 of the Act was carried out in Suraj Group of cases on 18.12.2013. Certain incriminating documents belonging to the assessee was found during the course of search proceeding. Therefore, the AO initiated proceeding u/s. 153C of the Act against the assessee. The assessment was completed u/s. 143(3) r.w.s. 153C

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