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    <title>2026 (6) TMI 1113 - ITAT DELHI</title>
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    <description>For a non-searched person, the six-year block under section 153C is computed from the date the seized material is received by the jurisdictional Assessing Officer, not from the date of search in the searched person&#039;s case. On that settled position, an assessment for the search-related year had to be framed under section 153C read with section 153A; use of section 143(3) was a fatal jurisdictional defect. The assessment was therefore held void for want of jurisdiction and not sustained, the Revenue&#039;s appeal was dismissed, and the first appellate order was upheld on the jurisdictional issue.</description>
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    <pubDate>Fri, 15 May 2026 00:00:00 +0530</pubDate>
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      <title>2026 (6) TMI 1113 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=793732</link>
      <description>For a non-searched person, the six-year block under section 153C is computed from the date the seized material is received by the jurisdictional Assessing Officer, not from the date of search in the searched person&#039;s case. On that settled position, an assessment for the search-related year had to be framed under section 153C read with section 153A; use of section 143(3) was a fatal jurisdictional defect. The assessment was therefore held void for want of jurisdiction and not sustained, the Revenue&#039;s appeal was dismissed, and the first appellate order was upheld on the jurisdictional issue.</description>
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      <pubDate>Fri, 15 May 2026 00:00:00 +0530</pubDate>
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