https://www.taxtmi.com/caselaws?id=795828 For an "other person", the first proviso to section 153C(1) treats the date on which seized material is received by that person's jurisdictional Assessing Officer as the deemed search-initiation date. The note explains that this date determines the relevant assessment years and the exclusion under section 153C(3). Where receipt of material and recording of satisfaction occurred after 1 April 2021, section 153C could not be invoked despite the original search having occurred earlier. It rejects the view that the legal fiction applies only to assessment-year computation, indicating that resulting notices and assessments lack jurisdiction. en-us Fri, 24 Jul 2026 00:00:00 +0530 Tue, 28 Jul 2026 08:30:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795828 For an "other person", the first proviso to section 153C(1) treats the date on which seized material is received by that person's jurisdictional Assessing Officer as the deemed search-initiation date. The note explains that this date determines the relevant assessment years and the exclusion under section 153C(3). Where receipt of material and recording of satisfaction occurred after 1 April 2021, section 153C could not be invoked despite the original search having occurred earlier. It rejects the view that the legal fiction applies only to assessment-year computation, indicating that resulting notices and assessments lack jurisdiction. Case-Laws Income Tax Fri, 24 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795828