Limitation Period u/s 153C commenced from date of receipt of seized material by AO and not from date of search or notice

Sunil Khetpalia Vs ACIT (Madras High Court) Conclusion: Under Section 153C, the six-year limitation period for issuing a notice to a person other than the one searched begins from the date on which the documents or materials were received by AO, not from the date of the search or notice. Held: Assessee had filed writ petitions challenging notices under Section 153C dated 30 December 2024 and assessment orders dated 13 March 2025 for the assessment years 2017-18 and 2018-19. A search was conducted on 09 November 2017, after which assessee settled the matter before the Interim Board for Settle...