Search Assessment Barred: Limitation Period Starts When AO Gets Seized Papers

DCIT Vs Ashwani Kumar Gupta (ITAT Delhi) ITAT Delhi: Section 153C block period reckoning must be from date of receipt of seized material by AO of other person — not from date of search Delhi ITAT dismissed Revenue’s appeals, holding that assessment u/s 153C was barred by limitation since the block period had to be counted from the date of receipt of seized documents by AO of other person, not from the date of search. A search was conducted on Alankit Group on 18-10-2019 & certain seized papers were later found to pertain to the Assessee. These were handed over to AO of the Assessee on ...