Section 153C Six-Year Block Runs From Satisfaction Note Date

DCIT Vs Basheshar Dayal HUF (ITAT Delhi) 153C Time-Bar Strikes Again — SLP Pending Can’t Stretch Limitation Beyond Six Years Delhi ITAT dismissed Revenue’s batch appeals in group cases of Basheshar Dayal, Ankur Gupta (HUF) & Anisha Gupta, holding that assessments framed u/s 153C beyond six AYs were barred by limitation. Tribunal upheld CIT(A)’s view that the six-year block has to be reckoned with reference to the AY in which the satisfaction note was recorded / seized material was handed over to AO of non-searched person, and not otherwise. Since satisfaction note dated 10-05-2022 ...