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For assessment under s.153C, the dominant issue was whether the "date of search" for computing the ten relevant assessment years is the original search date in the searched person's case or the date on which seized material was received by the AO of the non-searched person under the first proviso to s.153C(1). Applying Explanation (1) to s.153A, the Tribunal held that the receipt date is deemed to be the search date for the non-searched person, and the ten assessment years must be counted backward from the end of the assessment year relevant to the previous year in which such deemed search occurred. Since receipt occurred in AY 2022-23, AY 2012-13 fell outside the permissible block; the Revenue's appeal failed. - ITAT
For assessment under s.153C, the dominant issue was whether the "date of search" for computing the ten relevant assessment years is the original search date in the searched person's case or the date on which seized material was received by the AO of the non-searched person under the first proviso to s.153C(1). Applying Explanation (1) to s.153A, the Tribunal held that the receipt date is deemed to be the search date for the non-searched person, and the ten assessment years must be counted backward from the end of the assessment year relevant to the previous year in which such deemed search occurred. Since receipt occurred in AY 2022-23, AY 2012-13 fell outside the permissible block; the Revenue's appeal failed. - ITAT
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