https://www.taxtmi.com/caselaws?id=470386 For an 'other person' under Section 153C, the relevant search date is when the jurisdictional Assessing Officer receives the seized material. Where receipt and satisfaction occurred after 1 April 2021, Section 153C proceedings could not be initiated; the notices and consequential assessments for the earlier assessment years were therefore without jurisdiction. A conditional disclosure of unaccounted jewellery purchases, unsupported by independent evidence and contradicted by reconciliations and transaction records, could not support addition of the full purchase value. Only the embedded profit was taxable, and the addition was confined to 2% of the alleged purchases. en-us Tue, 17 Mar 2026 00:00:00 +0530 Fri, 24 Jul 2026 21:47:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470386 For an 'other person' under Section 153C, the relevant search date is when the jurisdictional Assessing Officer receives the seized material. Where receipt and satisfaction occurred after 1 April 2021, Section 153C proceedings could not be initiated; the notices and consequential assessments for the earlier assessment years were therefore without jurisdiction. A conditional disclosure of unaccounted jewellery purchases, unsupported by independent evidence and contradicted by reconciliations and transaction records, could not support addition of the full purchase value. Only the embedded profit was taxable, and the addition was confined to 2% of the alleged purchases. Case-Laws Income Tax Tue, 17 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470386