https://www.taxtmi.com/caselaws?id=444349 Interpretation of the proviso to the assessment provision for third parties resolves whether the six year limitation for filing returns runs from the date materials are forwarded or from the date of search and seizure. The court construed the proviso to govern both abatement and the commencement of the limitation period, reasoning that treating the seizure date as the start would unfairly prejudice uninvolved third parties if materials are forwarded much later. Consequence: the limitation begins from the date of forwarding of materials to the third party's assessing officer, and the appeal was dismissed. en-us Tue, 26 Sep 2023 00:00:00 +0530 Tue, 10 Feb 2026 17:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444349 Interpretation of the proviso to the assessment provision for third parties resolves whether the six year limitation for filing returns runs from the date materials are forwarded or from the date of search and seizure. The court construed the proviso to govern both abatement and the commencement of the limitation period, reasoning that treating the seizure date as the start would unfairly prejudice uninvolved third parties if materials are forwarded much later. Consequence: the limitation begins from the date of forwarding of materials to the third party's assessing officer, and the appeal was dismissed. Case-Laws Income Tax Tue, 26 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444349