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The ITAT addressed the issuance of notice under Section 153C, holding that the Assessing Officer's (AO) action for the other person shall be limited to six years from the date of receipt of seized material, irrespective of the original search date. The Supreme Court clarified that the date of receipt of seized material cannot be construed as the date of search, and requiring assessees to maintain records for extended periods is impractical. Consequently, the AO is competent to take action only for the six years preceding the receipt of seized material, rendering the search date irrelevant in determining the assessment period.
The ITAT addressed the issuance of notice under Section 153C, holding that the Assessing Officer's (AO) action for the other person shall be limited to six years from the date of receipt of seized material, irrespective of the original search date. The Supreme Court clarified that the date of receipt of seized material cannot be construed as the date of search, and requiring assessees to maintain records for extended periods is impractical. Consequently, the AO is competent to take action only for the six years preceding the receipt of seized material, rendering the search date irrelevant in determining the assessment period.
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