Section 153 c

[AK garg]

The provision in section 153 c (1) is that the search date in case of third person is to be construed as the date of handing over documents to the AO of third person. Is this provision only for the purpose of reckoning six years period alone? Is the date of search so construed can be deemed to be date of search for all purposes in case of third party? I mean if search has taken place in 2014 before amendment to 153 c incorporating ' relate to ' and the handingover of documents as well as notice to third party is served in 2016 after the amendment in section 148, saying that the material seized did not belong to but merely pertained to him taking shelter under the pre amended provision o 153 c, will such notice become invalid because search has to be construed from the date of handing over which is after amendment?

AI Summary

Search date for third-party searches: handing over documents may determine limitation and notice validity post-amendment Whether the search date for a third person is the date of handing over seized documents to that person's AO and whether that deeming is limited to computing the limitation period or applies generally to determine validity of subsequent notices, particularly when an original search predates an amendment and handing over and notice occur after the amendment.