https://www.taxtmi.com/caselaws?id=756589 Delhi HC held that Section 153C applies uniformly to all non-searched entities regardless of whether the assessing officer (AO) for searched and non-searched entities is the same person. The court rejected arguments for creating exceptions based on common jurisdiction. The formation of AO's satisfaction that seized materials likely impact the non-searched person's income determination constitutes the core requirement, not mere document transmission. Even where the same AO handles both entities, the commencement date for six-year limitation period begins when the AO records satisfaction regarding the non-searched entity's liability for reassessment proceedings. en-us Fri, 02 Aug 2024 00:00:00 +0530 Mon, 05 Aug 2024 13:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756589 Delhi HC held that Section 153C applies uniformly to all non-searched entities regardless of whether the assessing officer (AO) for searched and non-searched entities is the same person. The court rejected arguments for creating exceptions based on common jurisdiction. The formation of AO's satisfaction that seized materials likely impact the non-searched person's income determination constitutes the core requirement, not mere document transmission. Even where the same AO handles both entities, the commencement date for six-year limitation period begins when the AO records satisfaction regarding the non-searched entity's liability for reassessment proceedings. Case-Laws Income Tax Fri, 02 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756589