2024 (4) TMI 1201

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....n, Mr.Nischay, Kantoor and Ms.Soniya Dodeja, Advs. For the Respondent : Mr. Sanjay Kumar and Ms. Easha, Advs ORDER 1. These writ petitions have been preferred against the impugned notices dated 05 September 2022 issued under Section 153C of the Income Tax Act, 1961 ["Act"] for Assessment Year ["AY"] 2010-11 [W.P.(C) 3092/2023], and AY 2011-12 [W.P.(C) 3417/2023] and all consequential proceeding....

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....purposes of computation of the six and the ten year period is governed by the First Proviso to Section 153C, which significantly shifts the reference point spoken of in Section 153A(1), while defining the point from which the period of the "relevant assessment year" is to be calculated, to the date of receipt of the books of accounts, documents or assets seized by the jurisdictional AO of the non-....

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....elevant to the previous year of search. The block of six AYs' would consequently be those which immediately precede the AY relevant to the year of search. In the case of a search assessment undertaken in terms of Section 153C, the solitary distinction would be that the previous year of search would stand substituted by the date or the year in which the books of accounts or documents and assets sei....