TaxTMI 
TaxTMI 
2025 (12) TMI 271
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.... in all the appeals of the Revenue they were heard together and are disposed of by this common order for the sake of convenience and brevity. 3. The challenge in the grounds raised by the Revenue is in respect of the ld. CIT(A)'s action in holding that block periods for assessment u/s 153C of the Act have to be calculated from the date of receipt of the books of account, documents or assets seized by the Assessing Officer of the non-searched person and not from the date of initiation of search by relying upon the first proviso to section 153C of the Incometax Act, 1961 [the Act, for short]. 4. None appeared on behalf of the assessee in the case of Chandra Vidya Investment and Finance [Pvt] Ltd, hence the case is decided with the assis....
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....it is to be determined which are the ten assessment years immediately preceding the assessment year relevant to the previous year in which search is conducted or requisition is made. 8. This issue of the date of search for persons covered under section 153C and the calculation of ten preceding assessment years from the end of the relevant assessment year, is no longer res-integra. It has now been well settled by the Hon'ble Supreme Court in the case of CIT Vs. Jasjit Singh 458 ITR 437(SC). The relevant law laid down by the Hon'ble Supreme Court in the case of CIT Vs. Jasjit Singh 458 ITR 437(SC) are read as under: "It is evident on a plain interpretation of Section 153C(1) that the Parliamentary intent to enact the provi....
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....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-searched person. The shift of the relevant date in the case of a non-searched person being regulated by the First Proviso of Section 153C(1) is an issue which is no longer res integra and stands authoritatively settled by virtue of the decisions of this Court in SSP Aviation Ltd v. Dy.CIT (2012) 346 ITR 177 ( Delhi)( HC) and CIT v. RRJ Securities Ltd 2015 SCC Online Del 13085 as well as the decision of the Supreme Court in CIT v Jasjit Singh 2023 SCC Online SC1265. The afore....
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....searched person becomes date of search in the case of nonsearched person [the assessee in the present case]. 11. In accordance with the legal dictum laid down by the Courts as above, in the instant case, when the AO of the assessee recorded his satisfaction on 24.06.2022, for issuance of notice u/s 153C dated 09.09.2022, the assessment year relevant to the previous year in which search is conducted or requisition is made, as per the proviso of section 153C, becomes AY 2023-24. The ten assessment years immediately preceding the assessment year relevant to the previous year in which search is conducted or requisition is made, commences from AY 2023-24 upto AY 2014-15. As a consequence, the last of the ten A.Ys for which the Assessing Offic....