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“extension of limitation”

Assessment ProceduresSection 153Section 153561 judgments

The decision most relied on for extension of limitation is Collector, Land Acquisition, Anantnag & Anr. v. Mst. Katiji & Ors. (2 SCC 107), cited in 451 judgments on BharatTax.

Leading authorities on extension of limitation

Collector, Land Acquisition, Anantnag & Anr. v. Mst. Katiji & Ors.
2 SCC 107 · 1987 · Supreme Court
451
citing judgments

Courts must adopt a liberal approach when considering applications for condonation of delay, preferring to decide cases on their merits rather than allowing technicalities of limitation to scuttle justice. This principle applies to ensure the substantive rights of parties are not defeated by minor delays.

Income Tax, (1989) 111 ITR 377 (SC) and Jonas Woodhead and Sons (India) Limited v. CIT
224 ITR 342 · 1997 · Supreme Court
60
citing judgments

Expenditure incurred for the expansion, extension, or betterment of an existing business, or for improvisation that is part of the existing business, is allowable as revenue expenditure. Payments made for acquiring technical know-how and exclusive rights for setting up a new business can be capital expenditure.

CIT v. Bajrang Textiles
294 ITR 561 · 2007 · High Court
50
citing judgments

A direction for special audit under Section 142(2A), issued near the expiry of the limitation period primarily to gain an extension of time or with instructions beyond the section's scope, is illegal, rendering the subsequent assessment time-barred.

Koteswar Vittal Kamath v. K. Rangappa Baliga & Co.
1 SCC 255 · 1969 · Reported
43
citing judgments

When a new statutory provision is substituted for an existing one, the legislative intent is typically that the old provision is deemed deleted and does not remain in force unless there is a clear intention to keep it alive.

Ganesh Dass Khanna v. Income Tax Officer
156 Taxmann.com 417 · 2023 · High Court
34
citing judgments

The time limits for reopening assessments under the new regime are reduced to three years, with an extension to ten years only for serious tax evasion cases involving concealment of Rs. 50 lakhs or more.

Godrej Industries Ltd. v. Assistant Commissioner of Income-tax
160 Taxmann.com 13 · 2024 · High Court
21
citing judgments

A notice issued under section 148 for AY 2014-15 is invalid if issued by the Jurisdictional Assessing Officer instead of a Faceless Assessing Officer, especially when the extended period of 6 years under section 149 may not apply.

Delhi in ACIT v. Soul Space
117 Taxmann.com 395 · 2020 · High Court
18
citing judgments

An order for special audit under Section 142(2C) of the Income Tax Act must be passed within the prescribed time, including any extensions. An assessment order based on a special audit report submitted beyond the permissible period is void.

08 (Del) 4. CIT vs. S.K. Katyal, (2009) 308 ITR 168 (Del) 5. Golderest Finance (India) Ltd. v. DCIT
334 ITR 240 · 2011 · High Court
15
citing judgments

The Revenue Authorities cannot make a reference for assessment years if no information could have been provided for those years, and any extension of limitation based on such an invalid reference is impermissible.

Judgments citing extension of limitation

Ajith Padival, Bengaluru vs. Deputy Commissioner of Income Tax, Circle 4(3)(1), Represented by Assistant Director of Income Tax, CPC, Bangalore

In the result, the appeal by the assessee is allowed

ITA 660/BANG/2021[2018-19]Status: DisposedITAT Bangalore31 Jan 2022AY 2018-19

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2018-19

For Appellant: Shri Shankar D., CAFor Respondent: Shri K. Sankarganesh, Jt.CIT(DR)(ITAT), Bengaluru
Section 139Section 139(1)Section 143(1)Section 2Section 36(1)(va)Section 43BSection 6

question No. 1 framed in these appeals in the negative. 10. Further he relied on the following judgments:- 1. In Re-Cognizance for Extension of Limitation - Supreme Court of India in M.P No.665/2021 in SMW(C) No.3/2020 dt.19/7/2021. 2. Salzgitter Hydraulics Pvt Ltd vs ITO [2021] 128 taxman.com 192 [Hyderabad

Jayarama Reddy, Bangalore vs. Deputy Commissioner of Income Tax, CPC, Bangalore

In the result, the appeal by the assessee is allowed

ITA 657/BANG/2021[2019-20]Status: DisposedITAT Bangalore31 Jan 2022AY 2019-20

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2019-20

For Appellant: Shri Shambu Sharma, CAFor Respondent: Shri K. Sankarganesh, Jt.CIT(DR)(ITAT), Bengaluru
Section 139Section 139(1)Section 2Section 36(1)(va)Section 43BSection 6

question No. 1 framed in these appeals in the negative. 10. Further he relied on the following judgments:- 1. In Re-Cognizance for Extension of Limitation - Supreme Court of India in M.P No.665/2021 in SMW(C) No.3/2020 dt.19/7/2021. 2. Salzgitter Hydraulics Pvt Ltd vs ITO [2021] 128 taxman.com 192 [Hyderabad

Thoughtspot India Private Limited, Bengluru vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, the appeal by the assessee is allowed

ITA 493/BANG/2021[2019-20]Status: DisposedITAT Bangalore31 Jan 2022AY 2019-20

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2019-20

For Appellant: Shri Shankar D., CAFor Respondent: Shri K. Sankarganesh, Jt.CIT(DR)(ITAT), Bengaluru
Section 139Section 139(1)Section 143Section 143(1)Section 36(1)(va)Section 43B

question No. 1 framed in these appeals in the negative. 10. Further he relied on the following judgments:- 1. In Re-Cognizance for Extension of Limitation - Supreme Court of India in M.P No.665/2021 in SMW(C) No.3/2020 dt.19/7/2021. 2. Salzgitter Hydraulics Pvt Ltd vs ITO [2021] 128 taxman.com 192 [Hyderabad

Hotel Owner'S Credit Co-Operative Society, Mysuru vs. Income Tax Officer, Ward-1(1), Mysuru

In the result, the appeal filed by the assessee is partly allowed

ITA 368/BANG/2021[2015-16]Status: DisposedITAT Bangalore27 Jan 2022AY 2015-16

Bench: Shri George George K, Jm & Shri B.R.Baskaran, Am

For Appellant: Sri.Rampriya Das CAFor Respondent: Sri.Pradeep Kumar, CIT-DR
Section 143(3)Section 263Section 57(2)Section 80Section 80P

time limit from time to time due to Covid-19 Pandemic by the Hon’ble Apex Court in the case of Cognizance For Extension of Limitation reported in (2021) 438 ITR 296 (SC), the learned AR submitted that there is no delay in filing this appeal. The learned Departmental Representative ... duly heard. 4. In view of the judgment of the Hon’ble Apex Court in the case of Cognizance For Extension of Limitation (supra), which has extended the time limit for filing an appeal from time to time, we hold that there is no delay in filing this appeal

Vidhi Clothing Company, Bengaluru vs. The Deputy Commissioner of Income Tax, CPC, Bangalore

In the result, the appeal of the assessee is allowed

ITA 424/BANG/2021[2019-20]Status: DisposedITAT Bangalore05 Jan 2022AY 2019-20

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2019-20

For Appellant: Smt. Suman Lunkar, CAFor Respondent: Shri Sankarganesh K, JCIT (DR)
Section 139(1)Section 143Section 143(1)Section 143(1)(a)Section 234ASection 250Section 36(1)(va)Section 43B

these appeals in the negative. 9. Further, the ld.AR relied on the following judgments:- Page 9 of 12 1. In Re-Cognizance for Extension of Limitation - Supreme Court of India in M.P No.665/2021 in SMW(C) No.3/2020 dt.19/7/2021. 2. Salzgitter Hydraulics Pvt. Ltd vs. ITO [2021] 128 taxman.com 192 [Hyderabad

Genworks Health Private Limited, Bengaluru vs. Assistant Director of Income Tax, CPC, Bangalore

In the result, the appeal of the assessee is allowed

ITA 469/BANG/2021[2019-20]Status: HeardITAT Bangalore03 Jan 2022AY 2019-20

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2019-20

For Appellant: Shri K.R Vasudevan, AdvocateFor Respondent: Smt. Priyadarshini Besaganni, JCIT (DR)
Section 139Section 139(1)Section 143(1)Section 2Section 36(1)(va)Section 6

question No.1 framed in these appeals in the negative. 12. Further, the ld.AR relied on the following judgments:- 1. In Re-Cognizance for Extension of Limitation - Supreme Court of India in M.P No.665/2021 in SMW(C) No.3/2020 dt.19/7/2021. 2. Salzgitter Hydraulics Pvt. Ltd vs. ITO [2021] 128 taxman.com 192 [Hyderabad

M/S. Vijay Samraj Hotels Private Limited, Bangalore vs. The Assistant Commissioner of Income Tax, CPC, Bangalore

In the result, the appeal filed by the assessee is allowed

ITA 504/BANG/2021[2019-20]Status: DisposedITAT Bangalore28 Dec 2021AY 2019-20

Bench: Shri. B.R. Baskaran & Smt. Beena Pillaiassessment Year : 2019-20 M/S. Vijay Samraj Hotels P. The Assistant Ltd., Commissioner Of No. 18, 3Rd Main Road, Income Tax, Gandhinagar, Cpc, Bangalore – 560 009. Bangalore. Vs. Pan: Aabcv4731B Appellant Respondent Shri S.V. Ravishankar, Assessee By : Advocate & Ms. Sunaina Bhatia, Ca : Shri Raghavendra Rao, Addl. Revenue By Cit (Dr) Date Of Hearing : 01-12-2021 Date Of Pronouncement : 28-12-2021 Order Per Beena Pillaipresent Appeal By The Assessee Has Been Filed By Assessee Against The Order Dated 30.07.2021 Passed By The National Faceless Appeal Centre (Nfac), Delhi Relating To Assessment Year 2019-20 On Following Grounds Of Appeal: “1. The Impugned Order Of The Learned Commissioner Of Income-Tax (Appeals) National Faceless Appeal Centre, Bengaluru Karnataka Passed Under Section 250 Of The Income Tax Act, 1961 Is Opposed To Law, Weight Of Evidence, Probabilities, Facts & Circumstances Of The Appellant'S Case.

For Appellant: Advocate & Ms. Sunaina
Section 139(1)Section 143(1)Section 250Section 36(1)(va)Section 43B

outset, the Ld.AR submitted that there is a delay of 6 days in filing the present appeal. He submitted that extension of limitation period due to COVID-19 second wave was withdrawn Page 3 of 8 by Hon’ble Supreme Court vide order dated 23.09.2021, with effect from

Shand Pipe Industry Private Limited, Bengaluru vs. The Deputy Commissioner of Income Tax (CPC), Bengaluru

In the result, the appeal of the assessee is allowed

ITA 412/BANG/2021[2018-19]Status: DisposedITAT Bangalore27 Dec 2021AY 2018-19

Bench: Shri Chandra Poojari & Shri George George Kassessment Year : 2018-19

For Appellant: Smt. Suman Lunkar, C.AFor Respondent: Shri H Ananda, Addl.CIT (DR)
Section 139(1)Section 143Section 143(1)Section 143(1)(a)Section 234BSection 250Section 36Section 36(1)(va)Section 43B

question No.1 framed in these appeals in the negative. 12. Further, the ld.AR relied on the following judgments:- 1. In Re-Cognizance for Extension of Limitation - Supreme Court of India in M.P No.665/2021 in SMW(C) No.3/2020 dt.19/7/2021. Page 9 of 12 2. Salzgitter Hydraulics

Stirred Creative Advertising Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, CPC, Bengaluru

In the result, both the appeals of the assessee are allowed

ITA 594/BANG/2021[2018-19]Status: HeardITAT Bangalore13 Dec 2021AY 2018-19

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Smt. Susan Mathew, C.AFor Respondent: Shri Sankar Ganesh K, JCIT (DR)
Section 139Section 139(1)Section 143(1)Section 36(1)(va)Section 6

question No.1 framed in these appeals in the negative. 12. Further, the ld.AR relied on the following judgments:- 1. In Re-Cognizance for Extension of Limitation - Supreme Court of India in M.P No.665/2021 in SMW(C) No.3/2020 dt.19/7/2021. 2. Salzgitter Hydraulics Pvt. Ltd vs. ITO [2021] 128 taxman.com 192 [Hyderabad

Sh. Bhushan Lal Sawhney, New Delhi vs. DCIT, New Delhi

In the result, all the appeals of the Assessee are allowed

ITA 439/DEL/2017[2011-12]Status: DisposedITAT Delhi01 Jun 2021AY 2011-12

Bench: Shri Bhavnesh Saini & Shri B.R.R Kumar

For Appellant: Shri Somil Aggarwal, AdvocateFor Respondent: Shri Satpal Gulati, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)

case of Sunder Exports vs. DCIT, reported in (2009) 126 TTJ 0853) (Del), the ITAT, Delhi Bench held as under : “Assessment—Limitation—Extension of limitation under Explanation l(iii) to s. 153—As per the proviso to s. 142(2C) as applicable during the relevant asst ... DCIT vs. Ramachandra Dashrath Hande & Co., reported in (2010) 36DTR 0431 (Mum), the ITAT, Mumbai Bench, Mumbai held as under : “Assessment—Limitation—Extension of limitation under Expln.-1 (iii) to s. 153 - Prior to amendment in s.142(2C), the AO had no power to suo motu extend the period

Sh. Bhushan Lal Sawhney, New Delhi vs. DCIT, New Delhi

In the result, all the appeals of the Assessee are allowed

ITA 438/DEL/2017[2010-11]Status: DisposedITAT Delhi01 Jun 2021AY 2010-11

Bench: Shri Bhavnesh Saini & Shri B.R.R Kumar

For Appellant: Shri Somil Aggarwal, AdvocateFor Respondent: Shri Satpal Gulati, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)

case of Sunder Exports vs. DCIT, reported in (2009) 126 TTJ 0853) (Del), the ITAT, Delhi Bench held as under : “Assessment—Limitation—Extension of limitation under Explanation l(iii) to s. 153—As per the proviso to s. 142(2C) as applicable during the relevant asst ... DCIT vs. Ramachandra Dashrath Hande & Co., reported in (2010) 36DTR 0431 (Mum), the ITAT, Mumbai Bench, Mumbai held as under : “Assessment—Limitation—Extension of limitation under Expln.-1 (iii) to s. 153 - Prior to amendment in s.142(2C), the AO had no power to suo motu extend the period

Sh. Bhushan Lal Sawhney, New Delhi vs. DCIT, New Delhi

In the result, all the appeals of the Assessee are allowed

ITA 437/DEL/2017[2009-10]Status: DisposedITAT Delhi01 Jun 2021AY 2009-10

Bench: Shri Bhavnesh Saini & Shri B.R.R Kumar

For Appellant: Shri Somil Aggarwal, AdvocateFor Respondent: Shri Satpal Gulati, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)

case of Sunder Exports vs. DCIT, reported in (2009) 126 TTJ 0853) (Del), the ITAT, Delhi Bench held as under : “Assessment—Limitation—Extension of limitation under Explanation l(iii) to s. 153—As per the proviso to s. 142(2C) as applicable during the relevant asst ... DCIT vs. Ramachandra Dashrath Hande & Co., reported in (2010) 36DTR 0431 (Mum), the ITAT, Mumbai Bench, Mumbai held as under : “Assessment—Limitation—Extension of limitation under Expln.-1 (iii) to s. 153 - Prior to amendment in s.142(2C), the AO had no power to suo motu extend the period

Sh. Bhushan Lal Sawhney, New Delhi vs. DCIT, New Delhi

In the result, all the appeals of the Assessee are allowed

ITA 436/DEL/2017[2008-09]Status: DisposedITAT Delhi01 Jun 2021AY 2008-09

Bench: Shri Bhavnesh Saini & Shri B.R.R Kumar

For Appellant: Shri Somil Aggarwal, AdvocateFor Respondent: Shri Satpal Gulati, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)

case of Sunder Exports vs. DCIT, reported in (2009) 126 TTJ 0853) (Del), the ITAT, Delhi Bench held as under : “Assessment—Limitation—Extension of limitation under Explanation l(iii) to s. 153—As per the proviso to s. 142(2C) as applicable during the relevant asst ... DCIT vs. Ramachandra Dashrath Hande & Co., reported in (2010) 36DTR 0431 (Mum), the ITAT, Mumbai Bench, Mumbai held as under : “Assessment—Limitation—Extension of limitation under Expln.-1 (iii) to s. 153 - Prior to amendment in s.142(2C), the AO had no power to suo motu extend the period

Sh. Bhushan Lal Sawhney, New Delhi vs. DCIT, New Delhi

In the result, all the appeals of the Assessee are allowed

ITA 435/DEL/2017[2007-08]Status: DisposedITAT Delhi01 Jun 2021AY 2007-08

Bench: Shri Bhavnesh Saini & Shri B.R.R Kumar

For Appellant: Shri Somil Aggarwal, AdvocateFor Respondent: Shri Satpal Gulati, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)

case of Sunder Exports vs. DCIT, reported in (2009) 126 TTJ 0853) (Del), the ITAT, Delhi Bench held as under : “Assessment—Limitation—Extension of limitation under Explanation l(iii) to s. 153—As per the proviso to s. 142(2C) as applicable during the relevant asst ... DCIT vs. Ramachandra Dashrath Hande & Co., reported in (2010) 36DTR 0431 (Mum), the ITAT, Mumbai Bench, Mumbai held as under : “Assessment—Limitation—Extension of limitation under Expln.-1 (iii) to s. 153 - Prior to amendment in s.142(2C), the AO had no power to suo motu extend the period

Sh. Bhushan Lal Sawhney, New Delhi vs. DCIT, New Delhi

In the result, all the appeals of the Assessee are allowed

ITA 434/DEL/2017[2006-07]Status: DisposedITAT Delhi01 Jun 2021AY 2006-07

Bench: Shri Bhavnesh Saini & Shri B.R.R Kumar

For Appellant: Shri Somil Aggarwal, AdvocateFor Respondent: Shri Satpal Gulati, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)

case of Sunder Exports vs. DCIT, reported in (2009) 126 TTJ 0853) (Del), the ITAT, Delhi Bench held as under : “Assessment—Limitation—Extension of limitation under Explanation l(iii) to s. 153—As per the proviso to s. 142(2C) as applicable during the relevant asst ... DCIT vs. Ramachandra Dashrath Hande & Co., reported in (2010) 36DTR 0431 (Mum), the ITAT, Mumbai Bench, Mumbai held as under : “Assessment—Limitation—Extension of limitation under Expln.-1 (iii) to s. 153 - Prior to amendment in s.142(2C), the AO had no power to suo motu extend the period

Sh. Bhushan Lal Sawhney, New Delhi vs. DCIT, New Delhi

In the result, all the appeals of the Assessee are allowed

ITA 432/DEL/2017[2011-12]Status: DisposedITAT Delhi01 Jun 2021AY 2011-12

Bench: Shri Bhavnesh Saini & Shri B.R.R Kumar

For Appellant: Shri Somil Aggarwal, AdvocateFor Respondent: Shri Satpal Gulati, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)

case of Sunder Exports vs. DCIT, reported in (2009) 126 TTJ 0853) (Del), the ITAT, Delhi Bench held as under : “Assessment—Limitation—Extension of limitation under Explanation l(iii) to s. 153—As per the proviso to s. 142(2C) as applicable during the relevant asst ... DCIT vs. Ramachandra Dashrath Hande & Co., reported in (2010) 36DTR 0431 (Mum), the ITAT, Mumbai Bench, Mumbai held as under : “Assessment—Limitation—Extension of limitation under Expln.-1 (iii) to s. 153 - Prior to amendment in s.142(2C), the AO had no power to suo motu extend the period

Sh. Bhushan Lal Sawhney, New Delhi vs. DCIT, New Delhi

In the result, all the appeals of the Assessee are allowed

ITA 431/DEL/2017[2010-11]Status: DisposedITAT Delhi01 Jun 2021AY 2010-11

Bench: Shri Bhavnesh Saini & Shri B.R.R Kumar

For Appellant: Shri Somil Aggarwal, AdvocateFor Respondent: Shri Satpal Gulati, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)

case of Sunder Exports vs. DCIT, reported in (2009) 126 TTJ 0853) (Del), the ITAT, Delhi Bench held as under : “Assessment—Limitation—Extension of limitation under Explanation l(iii) to s. 153—As per the proviso to s. 142(2C) as applicable during the relevant asst ... DCIT vs. Ramachandra Dashrath Hande & Co., reported in (2010) 36DTR 0431 (Mum), the ITAT, Mumbai Bench, Mumbai held as under : “Assessment—Limitation—Extension of limitation under Expln.-1 (iii) to s. 153 - Prior to amendment in s.142(2C), the AO had no power to suo motu extend the period

Sh. Bhushan Lal Sawhney, New Delhi vs. DCIT, New Delhi

In the result, all the appeals of the Assessee are allowed

ITA 430/DEL/2017[2009-10]Status: DisposedITAT Delhi01 Jun 2021AY 2009-10

Bench: Shri Bhavnesh Saini & Shri B.R.R Kumar

For Appellant: Shri Somil Aggarwal, AdvocateFor Respondent: Shri Satpal Gulati, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)

case of Sunder Exports vs. DCIT, reported in (2009) 126 TTJ 0853) (Del), the ITAT, Delhi Bench held as under : “Assessment—Limitation—Extension of limitation under Explanation l(iii) to s. 153—As per the proviso to s. 142(2C) as applicable during the relevant asst ... DCIT vs. Ramachandra Dashrath Hande & Co., reported in (2010) 36DTR 0431 (Mum), the ITAT, Mumbai Bench, Mumbai held as under : “Assessment—Limitation—Extension of limitation under Expln.-1 (iii) to s. 153 - Prior to amendment in s.142(2C), the AO had no power to suo motu extend the period

Sh. Bhushan Lal Sawhney, New Delhi vs. DCIT, New Delhi

In the result, all the appeals of the Assessee are allowed

ITA 429/DEL/2017[2008-09]Status: DisposedITAT Delhi01 Jun 2021AY 2008-09

Bench: Shri Bhavnesh Saini & Shri B.R.R Kumar

For Appellant: Shri Somil Aggarwal, AdvocateFor Respondent: Shri Satpal Gulati, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)

case of Sunder Exports vs. DCIT, reported in (2009) 126 TTJ 0853) (Del), the ITAT, Delhi Bench held as under : “Assessment—Limitation—Extension of limitation under Explanation l(iii) to s. 153—As per the proviso to s. 142(2C) as applicable during the relevant asst ... DCIT vs. Ramachandra Dashrath Hande & Co., reported in (2010) 36DTR 0431 (Mum), the ITAT, Mumbai Bench, Mumbai held as under : “Assessment—Limitation—Extension of limitation under Expln.-1 (iii) to s. 153 - Prior to amendment in s.142(2C), the AO had no power to suo motu extend the period

Sh. Bhushan Lal Sawhney, New Delhi vs. DCIT, New Delhi

In the result, all the appeals of the Assessee are allowed

ITA 428/DEL/2017[2007-08]Status: DisposedITAT Delhi01 Jun 2021AY 2007-08

Bench: Shri Bhavnesh Saini & Shri B.R.R Kumar

For Appellant: Shri Somil Aggarwal, AdvocateFor Respondent: Shri Satpal Gulati, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)

case of Sunder Exports vs. DCIT, reported in (2009) 126 TTJ 0853) (Del), the ITAT, Delhi Bench held as under : “Assessment—Limitation—Extension of limitation under Explanation l(iii) to s. 153—As per the proviso to s. 142(2C) as applicable during the relevant asst ... DCIT vs. Ramachandra Dashrath Hande & Co., reported in (2010) 36DTR 0431 (Mum), the ITAT, Mumbai Bench, Mumbai held as under : “Assessment—Limitation—Extension of limitation under Expln.-1 (iii) to s. 153 - Prior to amendment in s.142(2C), the AO had no power to suo motu extend the period