ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, GUWAHATI vs. FORTUNE VANIJYA PRIVATE LIMITED, GUWAHATI
In the result both the appeal of the Revenue and the cross objections of the assessee stands partly allowed
ITA 21/GTY/2021[2011-12]Status: DisposedITAT Guwahati10 Dec 2021AY 2011-12
Bench: Shri P.M. Jagtap, Hon’Ble V.P (Kz) & Shri A. T. Varkey, Jm]
Section 132Section 132(4)Section 142(1)Section 153ASection 153CSection 68
147 of the Act, however the ratio decidendi will apply in the present case, because, like Section 147/148 of the Act, the AO gets the authority to assess/reassess the income of a searched person or other person u/s 153A/153C for the extended assessment years (7th to 10th AYs) only if he has in his possession the jurisdictional fact, as discussed
