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    <title>2025 (5) TMI 2245 - DELHI HIGH COURT</title>
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    <description>Whether assessments under Section 153C are barred by the limitation in Section 153B was decided by applying the statutory one year completion window measured from the end of the financial year in which seized documents were received by the Assessing Officer. The satisfaction note recorded delivery of relevant seized material to the Assessing Officer on 22.06.2022, so the assessment completion deadline fell at the end of the subsequent financial year; no assessment was completed within that period and the challenge notice therefore commenced proceedings that were time barred and were set aside.</description>
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      <description>Whether assessments under Section 153C are barred by the limitation in Section 153B was decided by applying the statutory one year completion window measured from the end of the financial year in which seized documents were received by the Assessing Officer. The satisfaction note recorded delivery of relevant seized material to the Assessing Officer on 22.06.2022, so the assessment completion deadline fell at the end of the subsequent financial year; no assessment was completed within that period and the challenge notice therefore commenced proceedings that were time barred and were set aside.</description>
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