https://www.taxtmi.com/caselaws?id=755496 The ITAT Delhi ruled against the revenue on two grounds. First, the assessment under Section 153C was invalid as the three mandatory conditions were not cumulatively satisfied - no incriminating materials were seized belonging to the assessee, and the AO failed to record proper satisfaction for relevant assessment years. The CIT(A)'s finding that additions were not based on seized documents was upheld. Second, regarding limitation, the tribunal held that for persons other than searched persons, the six-year block period runs from when satisfaction under Section 153C is recorded. Since satisfaction was recorded on 02.12.2016 (falling in AY 2017-18), assessments for AY 2009-10 and AY 2010-11 were beyond the permissible six-year block and therefore invalid. en-us Wed, 10 Jul 2024 00:00:00 +0530 Sat, 13 Jul 2024 08:22:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755496 The ITAT Delhi ruled against the revenue on two grounds. First, the assessment under Section 153C was invalid as the three mandatory conditions were not cumulatively satisfied - no incriminating materials were seized belonging to the assessee, and the AO failed to record proper satisfaction for relevant assessment years. The CIT(A)'s finding that additions were not based on seized documents was upheld. Second, regarding limitation, the tribunal held that for persons other than searched persons, the six-year block period runs from when satisfaction under Section 153C is recorded. Since satisfaction was recorded on 02.12.2016 (falling in AY 2017-18), assessments for AY 2009-10 and AY 2010-11 were beyond the permissible six-year block and therefore invalid. Case-Laws Income Tax Wed, 10 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755496