Date of Satisfaction, Not Search, Governs U/s 153C Limitation Period

DCIT Vs Goldline International Finvest Limited (ITAT Delhi) Date of Handover, Not Date of Search: Revenue Loses 153C Battle- Ten-Year Wall Holds Firm: Old AYs Safe from 153C Net In DCIT  Vs. Goldline International Finvest Ltd., ITA Nos.2898 & 2899/Del/2025, AYs 2011-12 & 2012-13, order dated 31.12.2025, Delhi ITAT dismissed Revenue’s appeals & upheld quashing of 153C assessments as time-barred beyond ten years. Search u/s 132 was conducted in Alankit Group on 18.10.2019. Based on alleged incriminating material, satisfaction notes were recorded in June 2022 & notice u/s 153C ...