#search and seizure assessment

When tax assessment relies on documents seized from a person other than the assessee, the Income Tax Appellate Tribunal mandates that Section 153C’s special assessment regime applies exclusively - overriding the general reassessment power under Section 147. This clarifies jurisdictional boundaries for assessing unrelated parties and prevents arbitrary reassessments based on unrelated search material.

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.