This case pertains to an appeal filed by Karina Airlines International Limited against the order of CIT (Appeals)-24, New Delhi, concerning the assessment year 2011-12. The primary contention revolves around the jurisdiction and validity of the assessment proceedings initiated under Section 153C of the Income Tax Act, 1961.
The appellant argued that the proceedings under Section 153C were invalid as they were based on satisfaction recorded after the stipulated period, making them barred by limitation. The tribunal considered precedents and statutory provisions to address the complex legal questions surrounding the initiation of proceedings under Section 153C.
The tribunal’s detailed examination of the case law and statutory interpretations led to a conclusion that favored the appellant, setting aside the assessment order due to procedural irregularities and jurisdictional errors. This case highlights the critical aspects of procedural compliance required in tax assessments and the implications of not adhering to statutory timelines.
The tribunal’s decision in this case underlines the importance of proper legal and procedural conduct in the assessment of tax liabilities and stresses the need for the assessing officer to adhere strictly to the provisions of the Income Tax Act.
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