Section 153C Assessments Beyond Six-Year Block Invalid: ITAT Delhi

Zenith Portfolio and Insurance Advisors Pvt. Ltd Vs DCIT (ITAT Delhi) Section 153C Assessments Beyond Six-Year Block Invalid: ITAT Delhi Quashes Proceedings The Delhi Bench of the ITAT quashed search assessments framed under section 153C for AYs 2013-14 to 2015-16, holding them to be barred by limitation and without valid jurisdiction. The Tribunal noted that the satisfaction note under section 153C was recorded on 17.12.2021 and, following the Supreme Court ruling in Jasjit Singh, the relevant “search year” for the assessee was AY 2022-23. Consequently, only the immediately preceding six ...