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Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
For a search assessment of an "other person" under section 153C, the relevant date for identifying the block of assessment years is when the seized material is handed over by the searched person's Assessing Officer to the jurisdictional Assessing Officer. As the satisfaction and handing over occurred on 26.03.2019, AY 2017-18 fell within the section 153C block. The AO's resort to section 143(3) was therefore without valid jurisdiction, and the assessment for AY 2017-18 was invalid on that basis. The ITAT upheld the Commissioner (Appeals) and rejected the Revenue's challenge.
For a search assessment of an "other person" under section 153C, the relevant date for identifying the block of assessment years is when the seized material is handed over by the searched person's Assessing Officer to the jurisdictional Assessing Officer. As the satisfaction and handing over occurred on 26.03.2019, AY 2017-18 fell within the section 153C block. The AO's resort to section 143(3) was therefore without valid jurisdiction, and the assessment for AY 2017-18 was invalid on that basis. The ITAT upheld the Commissioner (Appeals) and rejected the Revenue's challenge.
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