Date of receipt of seized documents relevant for reckoning block period of six AYs u/s. 153C: ITAT Delhi

Akansha Gupta Vs ACIT (ITAT Delhi) ITAT Delhi held that in respect of assessment proceedings u/s. 153C of the Income Tax Act, block period of six assessment years has to be reckoned from date of receipt of seized documents. Facts- A search and seizure action was carried out on 06.01.2021 in the cases of Hans Group/Praveen Jain/Janco Limited and the close associates and few transacting parties with whom the assessee Ms. Akansha Gupta had entered into unaccounted cash transactions. According to the AO, during the course of search action u/s 132 of the Act, certain documents/digital evidences in ...