https://www.taxtmi.com/caselaws?id=462803 ITAT Delhi held that AO exceeded jurisdiction under section 153C by initiating proceedings for assessment years 2011-12 and 2012-13, which fell outside the statutory 10-year block. The court determined that for non-searched persons, the 10-year block should be calculated from the date AO received seized material and recorded satisfaction (29.09.2021), making the valid block assessment years 2013-14 to 2022-23. Assessment orders for years 2011-12 and 2012-13 were quashed as void. Additionally, additions under section 69A were struck down for violating natural justice principles, as the assessee was denied cross-examination of a key witness whose statement formed the basis of assessment. The court noted that even the Enforcement Directorate had declared this witness unreliable. Furthermore, since AO himself found the assessee to be merely a pass-through entity with real beneficiaries elsewhere, no addition could be sustained. The assumption of jurisdiction under section 153C was declared invalid as proceedings cannot be initiated solely for protective additions. en-us Fri, 13 Sep 2024 00:00:00 +0530 Wed, 16 Jul 2025 17:21:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462803 ITAT Delhi held that AO exceeded jurisdiction under section 153C by initiating proceedings for assessment years 2011-12 and 2012-13, which fell outside the statutory 10-year block. The court determined that for non-searched persons, the 10-year block should be calculated from the date AO received seized material and recorded satisfaction (29.09.2021), making the valid block assessment years 2013-14 to 2022-23. Assessment orders for years 2011-12 and 2012-13 were quashed as void. Additionally, additions under section 69A were struck down for violating natural justice principles, as the assessee was denied cross-examination of a key witness whose statement formed the basis of assessment. The court noted that even the Enforcement Directorate had declared this witness unreliable. Furthermore, since AO himself found the assessee to be merely a pass-through entity with real beneficiaries elsewhere, no addition could be sustained. The assumption of jurisdiction under section 153C was declared invalid as proceedings cannot be initiated solely for protective additions. Case-Laws Income Tax Fri, 13 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462803