https://www.taxtmi.com/caselaws?id=780635 The dominant issue was whether a notice issued under s 153C on 07.02.2023 was barred by s 153C(3) as amended w.e.f. 01.04.2021. The HC held that the first proviso to s 153C(1) governs not merely abatement but also the relevant date for "initiation of search" for the "other person" under s 153C(3); for such person, the initiation date is when seized material is handed over to that person's jurisdictional AO. Since the handover occurred on 25.11.2022, the search was initiated after 01.04.2021, rendering s 153C inapplicable; the notices were without authority and were quashed. en-us Tue, 28 Oct 2025 00:00:00 +0530 Mon, 11 May 2026 11:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780635 The dominant issue was whether a notice issued under s 153C on 07.02.2023 was barred by s 153C(3) as amended w.e.f. 01.04.2021. The HC held that the first proviso to s 153C(1) governs not merely abatement but also the relevant date for "initiation of search" for the "other person" under s 153C(3); for such person, the initiation date is when seized material is handed over to that person's jurisdictional AO. Since the handover occurred on 25.11.2022, the search was initiated after 01.04.2021, rendering s 153C inapplicable; the notices were without authority and were quashed. Case-Laws Income Tax Tue, 28 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780635