Seized tax search material handover date as "search initiation" u/s153C(3), making s.153C notices invalid

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....The dominant issue was whether notices issued under s.153C were valid in view of s.153C(3) for searches initiated on or after 01.04.2021. The Tribunal held that the date on which seized material is handed over to the assessee's jurisdictional AO constitutes the "date of initiation of search" for purposes of s.153C(3). Since the handover occurred on 08.09.2022, s.153C stood excluded by statute, rendering the AO's notices dated 08.09.2022 without authority and contrary to s.153C(3). Consequently, all impugned s.153C notices were quashed and the assessee succeeded. - ITAT....