For Non-Searched Persons, Clock Starts on Receipt of Books – Revenue’s U/s 153C Theory Rejected

DCIT Vs Priyanka Gupta (ITAT Delhi) ITAT Delhi dismissed the Revenue’s appeal for AY 2021-22 in Priyanka Gupta (legal heir of late Smt. Neeru Gupta), upholding the relief granted by CIT(A) on the correct reckoning of limitation for a non-searched person. The Tribunal affirmed that where the assessee is not the searched person, the relevant date for computing the block/limitation is the date on which books of account or documents are received by the AO having jurisdiction over the other person, not the date of search. The CIT(A) had rightly followed binding Delhi HC precedents in PCIT v. Ojju...