Amendment to Section 153C by Finance Act, 2015 Applies to Searches Conducted Before Its Enactment

PCIT Vs Dharam Raj Construction & Infrastructure Private Limited (Delhi High Court)

The Delhi High Court reviewed an appeal by the Revenue challenging an Income Tax Appellate Tribunal (ITAT) decision regarding the application of Section 153C of the Income Tax Act to searches conducted before the 2015 Finance Act amendment. The case concerns Dharam Raj Construction and Infrastructure Private Limited, whose tax assessments for 2007-08 and 2008-09 had been disputed. Central to the case was the interpretation of the term “belongs to” in Section 153C, which was revised t

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