https://www.taxtmi.com/caselaws?id=759654 The ITAT Delhi held that an assessment under Section 153C for A.Y. 2011-12 was barred by limitation. The tribunal ruled that the six-year limitation period should be counted from the date of requisition of seized documents by the assessing officer, not from the search date. Since the requisition occurred in A.Y. 2018-19, the assessment for A.Y. 2011-12 fell outside the limitation period. Additionally, the satisfaction note for invoking Section 153C was found generic and vague, failing to identify specific seized material for the assessment year in question, making the assessment order invalid and requiring it to be quashed. en-us Mon, 30 Sep 2024 00:00:00 +0530 Sat, 05 Oct 2024 08:54:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759654 The ITAT Delhi held that an assessment under Section 153C for A.Y. 2011-12 was barred by limitation. The tribunal ruled that the six-year limitation period should be counted from the date of requisition of seized documents by the assessing officer, not from the search date. Since the requisition occurred in A.Y. 2018-19, the assessment for A.Y. 2011-12 fell outside the limitation period. Additionally, the satisfaction note for invoking Section 153C was found generic and vague, failing to identify specific seized material for the assessment year in question, making the assessment order invalid and requiring it to be quashed. Case-Laws Income Tax Mon, 30 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759654