Notices under Section 153C held time-barred; ten-year assessment period runs from date AO received seized materials, notices quashed

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....The HC held that notices issued under section 153C are time-barred and therefore invalid. Applying the governing limitation principle, the ten-year block for assessment is computed from the date on which the jurisdictional AO of the non-searched person received books, documents or assets seized from the jurisdictional AO of the searched person. On the facts, the relevant assessment years (AYs 2010-11 to 2015-16) fell outside the ten-year period as of the notice dates. Consequently, the petitions by the taxpayers were allowed and the impugned notices dated 31.08.2024 and 12.09.2024 issued under section 153C were quashed.....