Section 153C Assessments Beyond Ten-Year Block Invalid: Deemed Search Date Starts from Satisfaction Note

Advertisement Sri Sat Sahib Housing and Infrastructure Development company Vs DCIT/ACIT (ITAT Delhi) A search on a third party (Dalal Group) was conducted in September 2017, during which certain documents relating to the assessee were found. However, the Assessing Officer having jurisdiction over the assessee recorded the mandatory satisfaction for initiating proceedings under section 153C only on 19.03.2020. The Tribunal held that for a non-searched person, the “deemed date of search” is not the original search date of the third party but the date on which the Assessing Officer records...