Case Law Analysis
|Income Tax Appellate Tribunal
Section 153C IT Act | Limitation Period for Third-Party Search Assessments Begins from Satisfaction Note Date, Not Original Search : ITAT Delhi
ITAT Delhi rules that the 10-year block period for assessments under Section 153C of the Income Tax Act commences from the date of the satisfaction note recording incriminating material against the assessee, not the original search date. This holding invalidates assessments for AYs 2010-11 to 2013-14, reinforcing the jurisdictional High Court precedent in PCIT Vs. Ojjus Medicare Pvt. Ltd. and clarifying the limitation framework for search-based assessments.