Section 153C Assessment Beyond Ten-Year Block Period Invalid: ITAT Delhi

Advertisement DCIT Vs Betsy Growth Finance Ltd. (ITAT Delhi) The Delhi ITAT dismissed the Revenue’s appeals relating to assessment years 2010-11 and 2013-14, holding that the assessments framed under Section 153C of the Income-tax Act were barred by limitation. The Tribunal held that the ten-year block period under Section 153C must be reckoned from the date of recording of the satisfaction note or the date of issuance of notice under Section 153C, and not from the date of search. In the present case, the satisfaction note was recorded on 12 May 2022 and the notice under Section 153C was ...