Assessment u/s 153C beyond six assessment year is without jurisdiction

Dinesh Shah (HUF) Vs DCIT (ITAT Mumbai) ITAT Mumbai held that the assessment made u/s 153C of the Income Tax Act beyond the six assessment year is without jurisdiction and liable to be quashed. Facts- Pursuant to a search conducted on 10-12-2013 in the case of Ankur Shubham Group, it was found that the assessee was a key person of the said group, and since no search warrant was executed in the name of both the assessee’s, AO initiated proceedings u/s 153C after issuing notice in 2016, and since, the assessee being not the “searched person” for the purpose u/s 153A of the Act, for the pur...