https://www.taxtmi.com/caselaws?id=465379 The dominant issue was whether an assessment could validly be made under s.153C for an earlier AY beyond the six-year block. The ITAT held that, for the person other than the searched person, the date of recording satisfaction and handing over seized material is the deemed date of search; consequently, proceedings under s.153C can cover only six AYs preceding the year in which such satisfaction is recorded. On that basis, only AYs 2016-17 to 2021-22 were within scope, and the impugned AY (2012-13/2013-14) fell outside s.153C. Relying on binding HC ratios and SC authority, the deletion of the addition was upheld and the Revenue's appeal was dismissed. en-us Mon, 19 May 2025 00:00:00 +0530 Thu, 18 Dec 2025 22:30:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465379 The dominant issue was whether an assessment could validly be made under s.153C for an earlier AY beyond the six-year block. The ITAT held that, for the person other than the searched person, the date of recording satisfaction and handing over seized material is the deemed date of search; consequently, proceedings under s.153C can cover only six AYs preceding the year in which such satisfaction is recorded. On that basis, only AYs 2016-17 to 2021-22 were within scope, and the impugned AY (2012-13/2013-14) fell outside s.153C. Relying on binding HC ratios and SC authority, the deletion of the addition was upheld and the Revenue's appeal was dismissed. Case-Laws Income Tax Mon, 19 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465379