ITAT Delhi Quashes Additions Beyond Six-Year Limit Under Section 153C

DCIT Vs Kamalkunj Commercial P. Ltd. (ITAT Delhi) Delhi ITAT upheld the CIT(A)’s order deleting additions made u/s 153C, holding that the assessment years under consideration lay outside the permissible six-year block reckoned from the date of satisfaction/receipt of seized material, not from the date of search. A search u/s 132 was conducted on Net Ram Group on 12–13 March 2019. Based on seized documents indicating alleged fund layering through Kolkata-based entities, AO issued notice u/s 153C to the assessee on 09-08-2021. The CIT(A) quashed the assessment, following Supreme Court in CIT...