https://www.taxtmi.com/caselaws?id=794014 For an "other person" under section 153C, the operative date is the receipt of seized material by the Assessing Officer, and where that cannot be ascertained, the date of satisfaction becomes decisive; on the amended regime excluding searches initiated on or after 01.04.2021, a satisfaction note recorded on 11.10.2022 could not sustain section 153C proceedings, rendering the notice and assessment invalid. For an unabated assessment year, additions in search proceedings require incriminating material found during the search; as the section 69 addition was not shown to rest on such material, the addition for assessment year 2017-18 was unsustainable and the assessment order was quashed. en-us Wed, 24 Jun 2026 00:00:00 +0530 Sat, 27 Jun 2026 08:33:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794014 For an "other person" under section 153C, the operative date is the receipt of seized material by the Assessing Officer, and where that cannot be ascertained, the date of satisfaction becomes decisive; on the amended regime excluding searches initiated on or after 01.04.2021, a satisfaction note recorded on 11.10.2022 could not sustain section 153C proceedings, rendering the notice and assessment invalid. For an unabated assessment year, additions in search proceedings require incriminating material found during the search; as the section 69 addition was not shown to rest on such material, the addition for assessment year 2017-18 was unsustainable and the assessment order was quashed. Case-Laws Income Tax Wed, 24 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794014