Notice u/s. 153C beyond six years prior to relevant searched A.Y. is non-jurisdictional

Kamal Sharma Vs DCIT (ITAT Delhi)

ITAT Delhi held that issuance of notice under section 153C of the Income Tax Act beyond six years prior to relevant searched assessment year is beyond jurisdiction and accordingly liable to set aside.

Facts- Search was conducted in the case of Sunstar Group on 19.12.2013. Based on the material found, notice u/s. 153C of the Income-tax Act, 1961 was issued on 20.01.2016. He submitted that the deemed search for the purpose of section 153C is AY 2016-17. AO has issued notice u/s 153C to AYs falling within six assessment years i

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