Courier operator transshipping imported goods via designated air carrier, under transshipment bonds and strict Customs supervision, approved until 17....
For assessments under s.153C, the block period must be computed with reference to the date on which the seized books/documents/assets are received by the jurisdictional AO of the non-searched person, and not from the date of initiation of search. This follows the statutory scheme that uses "immediately preceding" for identifying the six assessment years, while Explanation 1 to s.153A requires the extended ten-year period to be reckoned "from the end of the assessment year," i.e., from 31 March of the AY relevant to the year of search; the computation must therefore align with these distinct legislative phrases. - ITAT
For assessments under s.153C, the block period must be computed with reference to the date on which the seized books/documents/assets are received by the jurisdictional AO of the non-searched person, and not from the date of initiation of search. This follows the statutory scheme that uses "immediately preceding" for identifying the six assessment years, while Explanation 1 to s.153A requires the extended ten-year period to be reckoned "from the end of the assessment year," i.e., from 31 March of the AY relevant to the year of search; the computation must therefore align with these distinct legislative phrases. - ITAT
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