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    <title>2025 (12) TMI 1183 - DELHI HIGH COURT</title>
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    <description>The dominant issue was limitation for assessments under s.153C, specifically the date from which the six assessment years are to be computed based on recording of satisfaction and handing over of seized material. The HC held that where the seized documents relating to the assessee were handed over to the assessee&#039;s AO and satisfaction was recorded on the same date, the six-year block must be counted from that date; consequently, AY 2013-14 falls outside the permissible period. The HC found no substantial question of law and upheld the Tribunal&#039;s dismissal; the revenue&#039;s appeal was dismissed.</description>
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      <title>2025 (12) TMI 1183 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=783643</link>
      <description>The dominant issue was limitation for assessments under s.153C, specifically the date from which the six assessment years are to be computed based on recording of satisfaction and handing over of seized material. The HC held that where the seized documents relating to the assessee were handed over to the assessee&#039;s AO and satisfaction was recorded on the same date, the six-year block must be counted from that date; consequently, AY 2013-14 falls outside the permissible period. The HC found no substantial question of law and upheld the Tribunal&#039;s dismissal; the revenue&#039;s appeal was dismissed.</description>
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