Third-Party Material Alone Can’t Trigger Section 153A for Unabated Years: ITAT Delhi

Orris Infrastructure Pvt. Ltd. Vs ACIT (ITAT Delhi) The case concerns a batch of appeals before the Delhi Bench of the Income Tax Appellate Tribunal involving assessments made under Section 153A of the Income-tax Act following a search conducted on 16 January 2013. For assessment years 2008–09 to 2011–12, the assessments were either completed earlier or had become final as on the date of search, and no proceedings were pending; these years were therefore treated as unabated. The Assessing Officer relied primarily on third-party material and statements seized during a separate search on ano...