Ten-Year Section 153A Block to Be Counted from AY of Search Year, Not Before

DCIT Vs Ankit Agarwal (ITAT Delhi)

Beyond 10-Year Block- Search Can’t Stretch Beyond Time Limit — ITAT Quashes 153A Notice for AY 2010–11 as Time-Barred

A search u/s 132 was conducted on Alankit Group on 18.10.2019, which also covered Assessee. Based on this, AO issued a notice u/s 153A on 02.09.2021 for AY 2010–11 & framed an assessment order. CIT(A), however, held that AY 2010–11 was beyond the 10-year block period permitted u/s 153A & accordingly quashed the assessment.

Revenue argued that Explanation 1 to Section 153A covered AY 2010–11 within

Please become a Premium member. If you are already a Premium member, login here to access the full content.