No special audit if CIT grants approval mechanically to extend limitation period

Rosy Blue (India) Pvt. Ltd. Vs DCIT (ITAT Mumbai)

Conclusion: Since AO had taken recourse to the provisions of section 142(2A) only with a view to extend the period of limitation by virtue of clause (iv) of Explanation 1 to section 153(9) for completion of assessment, without the conditions being satisfied in section 142(2A), therefore, the assessment framed by AO under section 143(3) was barred by limitation and invalid.

Held: The issue raised in assesse&

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