https://www.taxtmi.com/highlights?id=79884 Section 153C provisions are inapplicable as notice was issued to 'other person' under this section. Computation of six-year block period preceding assessment year relevant to previous year of search differs. For 'other person', block period starts from date of notice u/s 153C based on seized documents, not search date. Hence, for AY 2012-13, relevant block period is AY 2007-08 to 2012-13. Notice u/s 153C cannot reopen assessment for AY 2006-07. CIT(A)'s conclusion upheld, dismissing Revenue's appeal on jurisdictional grounds. en-us Tue, 30 Jul 2024 08:09:17 +0530 Tue, 30 Jul 2024 08:09:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=79884 Section 153C provisions are inapplicable as notice was issued to 'other person' under this section. Computation of six-year block period preceding assessment year relevant to previous year of search differs. For 'other person', block period starts from date of notice u/s 153C based on seized documents, not search date. Hence, for AY 2012-13, relevant block period is AY 2007-08 to 2012-13. Notice u/s 153C cannot reopen assessment for AY 2006-07. CIT(A)'s conclusion upheld, dismissing Revenue's appeal on jurisdictional grounds. Highlights Income Tax Tue, 30 Jul 2024 08:09:17 +0530 https://www.taxtmi.com/highlights?id=79884