No power to CIT in extending timeframe as AO was in seisin of assessment proceedings

PCIT Vs Soul Space Projects Ltd (Delhi High Court) Conclusion: Since the legislature vested the discretion to extend the timeframe solely in the AO, he could not have abdicated that function and confined his role to only making a recommendation to the CIT. CIT had no role in extending the timeframe as the AO was in seisin of the assessment proceedings. Held: Assessee was engaged in the business of construction and allied services and was subjected to a search action on 19.02.2008 under Section 132. Resultantly, a notice under Section 153A was issued to assessee by AO. Nearly eleven months late...