https://www.taxtmi.com/caselaws?id=448667 ITAT Delhi held that assessments under Section 153C for AY 2013-14, 2006-07, and 2007-08 were invalid and void ab initio as they fell outside the six-year limitation period. The tribunal clarified that for persons other than those searched, the relevant date for calculating the six assessment years is when the AO receives seized documents/assets, not the search date. Following SC precedent in Jasjit Singh case and HC judgment in RRJ Securities Ltd., the tribunal ruled that assessments beyond this limitation period lack jurisdiction. The assessment for AY 2012-13 under Section 143(3) was also deemed void. Decision favored the assessee. en-us Thu, 28 Dec 2023 00:00:00 +0530 Fri, 26 Jan 2024 15:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448667 ITAT Delhi held that assessments under Section 153C for AY 2013-14, 2006-07, and 2007-08 were invalid and void ab initio as they fell outside the six-year limitation period. The tribunal clarified that for persons other than those searched, the relevant date for calculating the six assessment years is when the AO receives seized documents/assets, not the search date. Following SC precedent in Jasjit Singh case and HC judgment in RRJ Securities Ltd., the tribunal ruled that assessments beyond this limitation period lack jurisdiction. The assessment for AY 2012-13 under Section 143(3) was also deemed void. Decision favored the assessee. Case-Laws Income Tax Thu, 28 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448667