ALZARAFA TRAVEL & MANPOWER CONSULTANTS (P) LTD,ERNAKULAM vs. ACIT, CENTRAL CIRCLE-2, , KOCHI

ITA 575/COCH/2025Status: DisposedITAT Cochin22 September 2025AY 2015-1615 pages
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What did the Tribunal hold?

The Tribunal held that the date of recording the satisfaction note (October 17, 2016) should be considered the date of receiving books of accounts for the purpose of Section 153C. Consequently, the assessment for AY 2015-16 was outside the permissible period under Section 153C.

What were the facts?

A search was conducted on the assessee on March 27, 2015. The Assessing Officer (AO) completed the assessment for AY 2015-16 under Section 153C. The assessee contended that the assessment should have been under Section 153A and that the AO lacked jurisdiction under Section 153C for AY 2015-16.

What were the issues?

The primary issue was whether the assessment for AY 2015-16 was validly completed under Section 153C, considering the date of the search and the period prescribed for such assessments.

Which sections of the Income-tax Act were involved?

Section 153C,Section 153A,Section 144

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Cases cited in this judgment(4)Show list

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## **IN THE INCOME TAX APPELLATE TRIBUNAL "DB" BENCH, COCHIN**

## **SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER ITA No.575/COCH/2025 (Assessment Year:2015-2016)**

## **Al Zarafa Travel & Manpower Consultants (P) Ltd.**

Elias George & Co, Chartered Accountants, Hig Avenue, Gandhi Nagar, Kerala- 682020

[PAN: AAFCA4935N] **…………. Appellant**

Vs

**Assistant Commissioner of Income Tax, Corporate Circle – 2(1), Kochi**

CR Building, IS Press Road, Kochi- 682018

**…………. Respondent**

#### **Appearance**

For the Appellant/Assessee For the Respondent/Department **: :** Shri Thomson Thomas Shri Sanjit Kumar Das

**Date**

Conclusion of hearing Pronouncement of order **: :** 21.08.2025 22.09.2025

#### **O R D E R**

## **Per Rahul Chaudhary, Judicial Member:

**

- 1. The present appeal preferred by the Assessee is directed against the order, dated 06/08/2025, passed by Commissioner of Income Tax, Appeal– Kochi- 3 [hereinafter referred to as 'the **CIT(A)**] under Section 250 of the Income Tax Act, 1961 [hereinafter referred to as 'the **Act**'] whereby the Ld. CIT(A) had dismissed the appeal against the Assessment Order, dated 05/03/2024, passed under

The order continues below.

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