https://www.taxtmi.com/caselaws?id=784096 The dominant issue was limitation for initiating assessment u/s 153C and computing the "ten relevant assessment years" when seized material is received by the AO of a non-searched person. The ITAT held that, by virtue of the first proviso to s.153C(1), the operative "date of search" for the non-searched person is the date on which the AO receives the seized records; consequently, the ten-year block must be counted backward under Expln. 1 to s.153A from the end of the AY relevant to the PY in which such receipt occurs. Since receipt occurred in AY 2022-23, the block ended at AY 2013-14, rendering AY 2012-13 outside scope; the Revenue's plea to adopt the original search date was rejected as contrary to binding HC precedent. en-us Thu, 27 Nov 2025 00:00:00 +0530 Fri, 26 Dec 2025 18:37:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784096 The dominant issue was limitation for initiating assessment u/s 153C and computing the "ten relevant assessment years" when seized material is received by the AO of a non-searched person. The ITAT held that, by virtue of the first proviso to s.153C(1), the operative "date of search" for the non-searched person is the date on which the AO receives the seized records; consequently, the ten-year block must be counted backward under Expln. 1 to s.153A from the end of the AY relevant to the PY in which such receipt occurs. Since receipt occurred in AY 2022-23, the block ended at AY 2013-14, rendering AY 2012-13 outside scope; the Revenue's plea to adopt the original search date was rejected as contrary to binding HC precedent. Case-Laws Income Tax Thu, 27 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784096