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ITAT held that for assessments under Section 153C involving non-searched persons, the limitation period for block assessment years must be calculated from the date of handing over incriminating material and recording satisfaction, not from the actual search date. Since notices under Section 153C were issued on 26.09.2019, making 2020-21 the search year for the assessee as "other person," assessments for AYs 2014-15 to 2019-20 fell within permissible block assessment periods. The Tribunal distinguished Section 153C assessments from Section 153A, establishing that the relevant date for determining the six-year block period is when seized materials are transferred to the jurisdictional assessing officer rather than the original search date. Decision favored revenue.
ITAT held that for assessments under Section 153C involving non-searched persons, the limitation period for block assessment years must be calculated from the date of handing over incriminating material and recording satisfaction, not from the actual search date. Since notices under Section 153C were issued on 26.09.2019, making 2020-21 the search year for the assessee as "other person," assessments for AYs 2014-15 to 2019-20 fell within permissible block assessment periods. The Tribunal distinguished Section 153C assessments from Section 153A, establishing that the relevant date for determining the six-year block period is when seized materials are transferred to the jurisdictional assessing officer rather than the original search date. Decision favored revenue.
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