https://www.taxtmi.com/caselaws?id=470443 For an "other person", receipt of seized material by that person's Assessing Officer determines the initiation date for section 153C proceedings; material handed over after 1 April 2021 barred recourse to section 153C, rendering the notice for assessment year 2020-21 without jurisdiction. Where unaccounted gold purchases and corresponding business sales were established, only the embedded gross-profit element was taxable; restriction to a 2% profit estimate was sustained. The same purchase transactions could not also be treated as unexplained expenditure under section 69C, as that would cause double taxation and no finding showed that the expenditure source remained unexplained. en-us Wed, 21 Jan 2026 00:00:00 +0530 Mon, 27 Jul 2026 19:07:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470443 For an "other person", receipt of seized material by that person's Assessing Officer determines the initiation date for section 153C proceedings; material handed over after 1 April 2021 barred recourse to section 153C, rendering the notice for assessment year 2020-21 without jurisdiction. Where unaccounted gold purchases and corresponding business sales were established, only the embedded gross-profit element was taxable; restriction to a 2% profit estimate was sustained. The same purchase transactions could not also be treated as unexplained expenditure under section 69C, as that would cause double taxation and no finding showed that the expenditure source remained unexplained. Case-Laws Income Tax Wed, 21 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470443