ITAT Delhi Quashed Section 153C Assessment for Failing ₹50 Lakh Threshold

DCIT Vs Mani Capital Limited (ITAT Delhi) 153C Assessment Quashed – Addition Below ₹50 Lakh Fails Monetary Threshold for Extended Block Period The Delhi ITAT dismissed the Revenue’s appeal and upheld the CIT(A)’s order quashing the assessment made under Section 153C for AY 2015-16 on jurisdictional grounds. The Tribunal held that for non-searched persons, the block period under Section 153C has to be computed from the date of receipt of seized material by the AO of the non-searched person, following PCIT v. Ojjus Medicare (Delhi HC). In the present case, although the search on the Alan...