2025 (5) TMI 2201

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..... Harpreet Kaur Hansra, Sr. DR. ORDER PER SATBEER SINGH GODARA, JUDICIAL MEMBER : This Revenue's appeal for Assessment Year 2021-22, arises against the CIT(A)/NFAC, Delhi's DIN & order No. ITBA/APL/M/250/2024-25/1069269543(1) dated 30.09.2024, in proceedings u/s 143(3) of the Income Tax Act, 1961 (in short "the Act"). 2. Heard both the parties at length. Case file perused. 3. T....

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....f the income-tax Act, 1961, have to be calculated from the date of receipt of the books of accounts, documents or assets seized, by the jurisdictional AO of the non-searched person, even when this interpretation is contrary to the legislative intent since for the years after the search there can never be incriminating seized material and as such assessment in years cannot be made u/s 163C of the A....

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.... 101 (Del.), PCIT vs. Jasjit Singh (2024) 336 CTR 634 (Delhi) and CIT Vs. RRJ Securities Ltd. (2016) 380 ITR 0612, it is the date of receipt of the search records which has to be taken as the date of search followed by initiation of section 153C proceedings which includes assessment year 2021-22 herein. Learned CIT(A), therefore, concludes that the impugned assessment framed u/s 143(3) is not sust....