Topic

non-searched person

2 articlesLatest June 2026
Section 153C IT Act | Block Period for Non-Search Assessments Starts from Receipt of Seized Docs, Not Search Date : ITAT Delhi
Case Law Analysis
|Income Tax Appellate Tribunal

Section 153C IT Act | Block Period for Non-Search Assessments Starts from Receipt of Seized Docs, Not Search Date : ITAT Delhi

The ITAT Delhi has ruled that for non-searched persons under Section 153C, the ten-year assessment block begins when the Assessing Officer receives seized documents - not from the date of the original search. This clarifies jurisdictional limits and protects taxpayers from retrospective assessments based on delayed document transfers, impacting thousands of pending cases involving third-party seizures.

Section 153C Income Tax Act | Six-Year Reopening Window Tied to Satisfaction Note Date, Not Search Date : ITAT Delhi
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.

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