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Search Assessment Quashed; Limitation Must Be Calculated Separately for Each Person

TaxGuru
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Summary

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  • The ITAT has quashed a search assessment, stating that limitation under Section 153B must be computed separately for each person involved.
  • This ruling emphasizes that the assessee's own last panchanama is the basis for determining the limitation period, even when a joint search warrant is issued.
  • The assessments in question were completed beyond the prescribed period, leading to their annulment.
  • This decision could significantly impact future assessments arising from joint searches and their procedural timelines.

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