https://www.taxtmi.com/caselaws?id=791196 Proceedings under section 153C were treated as time-barred because the six-year and ten-year block period had to be computed from the date of search, not from the later date when seized material was handed over to the jurisdictional Assessing Officer or satisfaction was recorded. The Tribunal read sections 153A and 153C together, relied on the Finance Act, 2017 scheme and the CBDT circular, and followed the binding judicial position that the block period cannot be shifted to the date of transfer of documents. On that basis, the limitation ground succeeded and the Revenue's challenge failed. en-us Fri, 17 Apr 2026 00:00:00 +0530 Wed, 06 May 2026 10:07:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791196 Proceedings under section 153C were treated as time-barred because the six-year and ten-year block period had to be computed from the date of search, not from the later date when seized material was handed over to the jurisdictional Assessing Officer or satisfaction was recorded. The Tribunal read sections 153A and 153C together, relied on the Finance Act, 2017 scheme and the CBDT circular, and followed the binding judicial position that the block period cannot be shifted to the date of transfer of documents. On that basis, the limitation ground succeeded and the Revenue's challenge failed. Case-Laws Income Tax Fri, 17 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791196