https://www.taxtmi.com/caselaws?id=794716 Section 153C proceedings against a person other than the searched person depend on when seized material is received or the satisfaction note is recorded for that person. Where the satisfaction note was recorded on 20.10.2021, after 01.04.2021, the amended bar in section 153C(3) applied and the assessments could not be sustained under section 153C. The Tribunal followed the view that the first proviso to section 153C(1) fixes the relevant date for initiation against the other person, and initiation after the cut-off date renders such proceedings unavailable. The assessments were therefore held invalid, void ab initio, and quashed. en-us Fri, 05 Jun 2026 00:00:00 +0530 Fri, 10 Jul 2026 07:39:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794716 Section 153C proceedings against a person other than the searched person depend on when seized material is received or the satisfaction note is recorded for that person. Where the satisfaction note was recorded on 20.10.2021, after 01.04.2021, the amended bar in section 153C(3) applied and the assessments could not be sustained under section 153C. The Tribunal followed the view that the first proviso to section 153C(1) fixes the relevant date for initiation against the other person, and initiation after the cut-off date renders such proceedings unavailable. The assessments were therefore held invalid, void ab initio, and quashed. Case-Laws Income Tax Fri, 05 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794716