Section 153C: Block Period to Be Counted from Date of Material Receipt, Not Date of Search

DCIT Vs Chetan Goyal (ITAT Delhi)

ITAT Delhi: Assessment under Section 153C Quashed – Block Period to Be Counted from Date of Material Receipt, Not Date of Search

Facts in Brief

During a search on Parveen K. Jain Group on 06.01.2021, a mobile phone was seized showing an image relating to a property at 451, Functional Industrial Estate, Patparganj, Delhi allegedly indicating a cash payment of ₹9.58 crore. The AO invoked Section 153C and added ₹3.78 crore as unexplained investment u/s 69, treating the Assessee, Chetan Goyal, as linked to th

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