Wrong Starting Point for Section 153C Renders Assessment Time-Barred

DCIT Vs Meena Mehra (ITAT Delhi) ITAT Delhi: For ‘Other Person’, Six-Year Block u/s 153C to Be Reckoned from Date of Receipt of Material / Satisfaction Note – Revenue Appeal Dismissed The Delhi Bench of the ITAT dismissed the Revenue’s appeal for AY 2021-22 and upheld the order of the CIT(A), holding that in the case of a person other than the searched person, the six-assessment-year block for the purpose of section 153C has to be computed from the date on which the books of account or seized material are received by the jurisdictional Assessing Officer and the satisfaction is recorded...