https://www.taxtmi.com/caselaws?id=760546 The ITAT Delhi held that assessment proceedings under section 153C were time-barred and improperly initiated. The tribunal determined that the deemed date of possession of seized documents was the date of recording satisfaction (03-10-2022), from which the six-year limitation period should be calculated. The relevant assessment years under section 153C were AY 2018-19 to 2022-23, with AY 2023-24 being the assessment year for the previous year when search was conducted. The assessment for AY 2021-22 should have been conducted under section 153C, not section 143(2). The assessment order under section 143(3) was quashed as bad in law. The assessee's appeal was allowed. en-us Tue, 15 Oct 2024 00:00:00 +0530 Tue, 22 Oct 2024 11:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760546 The ITAT Delhi held that assessment proceedings under section 153C were time-barred and improperly initiated. The tribunal determined that the deemed date of possession of seized documents was the date of recording satisfaction (03-10-2022), from which the six-year limitation period should be calculated. The relevant assessment years under section 153C were AY 2018-19 to 2022-23, with AY 2023-24 being the assessment year for the previous year when search was conducted. The assessment for AY 2021-22 should have been conducted under section 153C, not section 143(2). The assessment order under section 143(3) was quashed as bad in law. The assessee's appeal was allowed. Case-Laws Income Tax Tue, 15 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760546