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HC held that the limitation period for issuing notice u/s 153C commences from the date of seizure of documents (30.06.2022), not the search date (10.11.2020). The petitioner, being a third party, can respond to the show cause notice dated 30.12.2024 and contest the proceedings in accordance with law. Despite prior settlement at IBS, the Department retains liberty to proceed if new material emerges. The court found no merit in the petitioner's limitation argument and dismissed the writ petitions, upholding the impugned notice and order.
HC held that the limitation period for issuing notice u/s 153C commences from the date of seizure of documents (30.06.2022), not the search date (10.11.2020). The petitioner, being a third party, can respond to the show cause notice dated 30.12.2024 and contest the proceedings in accordance with law. Despite prior settlement at IBS, the Department retains liberty to proceed if new material emerges. The court found no merit in the petitioner's limitation argument and dismissed the writ petitions, upholding the impugned notice and order.
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