Six-Year Limit Under Section 153C Runs From Document Handover, Not Search Date

PCIT (Central) Vs Deepak Kumar Aggarwal (Delhi High Court) The Delhi High Court dismissed the Revenue’s appeal and upheld the view that, for proceedings under Section 153C of the Income Tax Act, 1961, the six-year limitation period must be reckoned from the date on which seized documents are handed over to the Assessing Officer (AO) of the “other person,” and not from the date of search. In the present case, a search under Section 132 was conducted on 02.11.2017 at the premises of a third party. During the search, documents pertaining to the assessee were found. The AO of the searched pe...