Time-Barred Section 153C Assessment Struck Down for Non-Searched Person

Quadra Infratel Synergies Pvt. Ltd. Vs ACIT (ITAT Delhi)

153C limitation counted from date of handover, not original search; ITAT Delhi quashes assessment as time-barred

Delhi  Tribunal allowed Assessee’s appeal &  quashed assessment u/s 153C as barred by limitation. Tribunal noted that search was conducted on a third party (A-Tek Enterprises) on 28-06-2018, but seized material was handed over to AO of Assessee only on 26-10-2021, &  satisfaction u/s 153

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