https://www.taxtmi.com/caselaws?id=449392 The ITAT Delhi held that an assessment under section 153C read with section 153A for AY 2008-09 was time-barred. The satisfaction note dated 02.02.2016 did not specify when materials were handed over, so this date was considered the handover date. Since AY 2008-09 fell beyond the six-year limitation period calculated from this date, the assessment was invalid. Additionally, following the SC decision in PCIT vs. Abhisar Buildwell Pvt. Limited, the tribunal ruled that additions under section 68 cannot be made without incriminating materials seized during search operations. The assessee's cross-objection was allowed. en-us Thu, 08 Feb 2024 00:00:00 +0530 Wed, 08 May 2024 17:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449392 The ITAT Delhi held that an assessment under section 153C read with section 153A for AY 2008-09 was time-barred. The satisfaction note dated 02.02.2016 did not specify when materials were handed over, so this date was considered the handover date. Since AY 2008-09 fell beyond the six-year limitation period calculated from this date, the assessment was invalid. Additionally, following the SC decision in PCIT vs. Abhisar Buildwell Pvt. Limited, the tribunal ruled that additions under section 68 cannot be made without incriminating materials seized during search operations. The assessee's cross-objection was allowed. Case-Laws Income Tax Thu, 08 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449392