PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

Facts

A search and seizure operation was conducted on Prathima Infrastructure Limited. During the search, incriminating material including handwritten cash sheets downloaded from an email account were found. The assessee argued that the assessment was time-barred based on the conclusion date of the search in their premises, while the Revenue contended it should be based on the last conclusion date from a joint warrant.

Held

The Tribunal held that the limitation period for assessment under Section 153B is determined by the conclusion date of the search as recorded in the last panchanama drawn concerning any person covered by the joint warrant of authorization. The assessment order was found to be within the prescribed time limit.

Key Issues

Whether the assessment order is barred by limitation under Section 153B, and whether additions based on email evidence are justified.