153C Time-Barred: ITAT Kolkata Quashes Notice Based on Seized Digital Material

Jaideep Halwasiya Vs ACIT (ITAT Kolkata) 153C Proceedings Time-Barred: ITAT Kolkata Quashes Notice Issued After 01.04.2021 Based on Handing-Over Date of Seized Digital Material The Kolkata Bench of the ITAT condoned a substantial delay of 326 days in filing the appeal by an NRI assessee and allowed the appeal on a pure question of law, holding that the proceedings initiated under Section 153C were invalid and void ab initio. The Tribunal held that for an “other person” under Section 153C, the date of initiation of search is the date on which the seized material is handed over by the AO of ...