Section 153C Prevails Over Section 144 for persons other than searched person

Al Zarafa Travel & Manpower Consultants (P) Ltd Vs ACIT (ITAT Cochin)

Satisfaction Note Date Controls – Tribunal Applies First Proviso to 153C- Cochin ITAT Quashes 144 Assessment – AO Should Have Invoked Section 153C

Assessee, engaged in manpower recruitment & supply, faced a search on 27.03.2015. Subsequently, assessment was framed u/s 144 r.w.s 153C assessing total income at over ₹428 crore. In earlier appellate rounds, relief was partly granted, and eventually assessment was reduced to ₹5.19 crore. The dispute persisted regarding jurisdiction: whether asse

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