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

Facts

A search and seizure operation was conducted on Prathima Infrastructure Limited and its associate entities. During the search, incriminating material including handwritten cash sheets and email data of an employee, P. Anil Kumar, were seized. The Assessing Officer made additions to income based on these seized documents, which were upheld by the CIT(A).

Held

The Tribunal held that the assessment order was time-barred. It reasoned that the search concluded in the assessee's case on 12.02.2020, and the subsequent conclusion date of 23.07.2020 cited by the Revenue, which involved a prohibitory order on a director's premises, did not extend the limitation period for the assessee. The Tribunal also noted that additions based on photocopied documents without corroboration were unsustainable.

Key Issues

Whether the assessment order was barred by limitation under Section 153B, considering the conclusion date of the search. Whether additions based on photocopied documents and uncorroborated evidence are valid.