Case Law Analysis
|Income Tax Appellate Tribunal
Section 153C Income Tax Act | Six-Year Reopening Window Tied to Satisfaction Note Date, Not Search Date : ITAT Delhi
The ITAT Delhi has ruled that assessments under Section 153C can only reopen income for six years preceding the date of the satisfaction note, not the search operation. This clarifies jurisdictional limits for non-searched persons and prevents retrospective expansion of assessments beyond the statutory window, offering critical relief to taxpayers caught in delayed post-search proceedings.