ITAT Delhi landmark order on scope of draconian provision of section 153C

DCIT Vs Dalmia Bharat and Industries Ltd. (ITAT Delhi)

Now the questions arising before us in this group of appeals were as Under:-

i. Whether assessment framed u/s 153C read with S; ection 143 (3) for assessment year 2006 – 07 and 2007 – 08 are barred by the limitation.

ii. Whether the assessment order passed for assessment year 2011–12 u/s 153C is without jurisdiction and void ab initio as no satisfaction has been recorded by the assessing officer of the
searched person

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