2025 (7) TMI 35

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....2024 of the Ld. Commissioner of Income-tax (Appeals)-28, New Delhi (hereinafter referred to as the 'Ld. First Appellate Authority or 'the Ld. FAA' in short) in appeals filed before him against the orders dated 09.03.2024 of the ld. Dy. Commissioner of Income-tax, Central Circle-25, New Delhi (hereinafter referred to as the Ld. AO, for short) passed u/s 153C/143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'). Further details of the orders of the ld. FAA are as under:- ITA No. & Assessment Year Appeal No. ITA No.2341/Del/2024, AY: 2010-11(A) 29/10034/2009-10 ITA No.2786/Del/2024, AY: 2010-11 (R) - Do - ITA No.2342/Del/2024, AY: 2011-12(A) 29/10055/2010-11 ITA No.2342/Del/2024, AY: 2012-13(A) ....

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....nsidered as 26.09.2019, the search year in the case of the present assessee as 'other person' would be 2020-21. In that case, assessments for AYs 2014-15 to 2019-20 would fall in the search years and the present assessment years fall beyond the block assessment periods. 5. Though the ld. DR has submitted that this amendment is prospective, however, the issue has been well considered in the case of Ojjus Medicare Pvt Ltd [2024] 61 taxmann.com 160 (Del) wherein it has held as under: "First Proviso to Section 153C introduces a legal fiction on the basis of which the commencement date for computation of the six year or the ten year block is deemed to be the date of receipt of books of accounts by the jurisdictional AO. The identific....