Assessment Orders u/s 153C Invalid for Pre-2017 Searches Due to Prospective Application of Finance Act 2017 Amendments.

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....Validity of assessment proceedings initiated u/s 153C - In case of other person u/s 153C of the Act, the starting point for computation of the block period would be the date from on which based on the seized documents, notice is issued to the other person - As further held that the amendment made in section 153C by Finance Act 2017 w.e.f. 1st April 2017 which states that block period for the “searched person” as well as the “other person” would be same six AYs immediately preceding the year of search is only prospective. It makes the things clear that the search that took place in this case is prior to amendment unaffected by the amendment made by way of Finance Act 2017. - assessment order passed u/s 153C of the Act, is wholly without jurisdiction, hence, invalid - AT....