This document provides a detailed analysis of the Income Tax Appellate Tribunal’s (ITAT) decision in the case of Karina Airlines International Limited versus the Assistant Commissioner of Income Tax (ACIT), Circle-05, New Delhi for the assessment year 2012-13, as adjudicated under ITA No. 203/DEL/2021.
Karina Airlines International Limited, engaged in helicopter services, faced extensive assessments and adjustments following a search and seizure operation. This led to several legal challenges regarding the validity of the proceedings under section 153C of the Income Tax Act.
The primary issues revolved around the jurisdictional validity of the assessment proceedings initiated under section 153C, and whether the assessment order was barred by limitation. The tribunal considered various legal precedents and statutory interpretations to address these challenges.
The tribunal’s decision focused on the correct application of law regarding the initiation of proceedings and the relevance of the assessment year to the date of search and subsequent actions. The tribunal’s findings were pivotal in determining the outcome of the appeal, ultimately leading to the quashing of the assessment order.
The tribunal’s ruling in favor of Karina Airlines underscores the importance of adhering to procedural and jurisdictional requirements in tax assessments. This case serves as a significant reference for similar cases involving issues of jurisdiction and limitation in tax proceedings.
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