https://www.taxtmi.com/caselaws?id=459859 The ITAT Delhi ruled against the Revenue in a case involving initiation of proceedings under Section 153C beyond the limitation period. The tribunal held that the first proviso to Section 153C, inserted by Finance Act 2005 with retrospective effect from June 1, 2003, created a distinction between searched persons and other persons regarding the relevant period for assessment and reassessment. For persons other than the searched person, Section 153A must be construed as referring to the date of receiving books of accounts, documents, or assets by the assessing officer having jurisdiction over such other person. The satisfaction note was recorded on October 14, 2016, and notice issued on October 18, 2016, which was found to be within the limitation period. en-us Fri, 30 Jun 2023 00:00:00 +0530 Tue, 31 Dec 2024 23:47:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459859 The ITAT Delhi ruled against the Revenue in a case involving initiation of proceedings under Section 153C beyond the limitation period. The tribunal held that the first proviso to Section 153C, inserted by Finance Act 2005 with retrospective effect from June 1, 2003, created a distinction between searched persons and other persons regarding the relevant period for assessment and reassessment. For persons other than the searched person, Section 153A must be construed as referring to the date of receiving books of accounts, documents, or assets by the assessing officer having jurisdiction over such other person. The satisfaction note was recorded on October 14, 2016, and notice issued on October 18, 2016, which was found to be within the limitation period. Case-Laws Income Tax Fri, 30 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459859