https://www.taxtmi.com/caselaws?id=770969 The ITAT Delhi dismissed the Revenue's appeal regarding proceedings under Section 153C being barred by limitation and additions under Section 68. The tribunal followed the Plaza Fincap precedent, clarifying that the six-year period for assessment years is calculated from those immediately preceding the assessment year relevant to the search year, while the ten-year period is reckoned from March 31st of the assessment year relevant to the search year. The court emphasized the statutory distinction between "immediately preceding" for the six-year period and "from the end of the assessment year" for the ten-year block. en-us Fri, 09 May 2025 00:00:00 +0530 Mon, 19 May 2025 08:37:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770969 The ITAT Delhi dismissed the Revenue's appeal regarding proceedings under Section 153C being barred by limitation and additions under Section 68. The tribunal followed the Plaza Fincap precedent, clarifying that the six-year period for assessment years is calculated from those immediately preceding the assessment year relevant to the search year, while the ten-year period is reckoned from March 31st of the assessment year relevant to the search year. The court emphasized the statutory distinction between "immediately preceding" for the six-year period and "from the end of the assessment year" for the ten-year block. Case-Laws Income Tax Fri, 09 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770969