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For a non-searched person, the relevant date for section 153C proceedings is the date on which the satisfaction note is recorded or seized material reaches the jurisdictional Assessing Officer. Applying the Supreme Court's ruling in Jasjit Singh and later Tribunal/High Court followings, the Tribunal treated the first proviso to section 153C(1) as governing the operative date for all practical purposes. Because the satisfaction note was recorded after 01.04.2021, section 153C ceased to be available and the proceedings were without jurisdiction. The assessments were therefore held void ab initio and quashed.
For a non-searched person, the relevant date for section 153C proceedings is the date on which the satisfaction note is recorded or seized material reaches the jurisdictional Assessing Officer. Applying the Supreme Court's ruling in Jasjit Singh and later Tribunal/High Court followings, the Tribunal treated the first proviso to section 153C(1) as governing the operative date for all practical purposes. Because the satisfaction note was recorded after 01.04.2021, section 153C ceased to be available and the proceedings were without jurisdiction. The assessments were therefore held void ab initio and quashed.
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