Computation Of 6 Assessment Years For Search Assessments U/S 153C Starts From Date Of Receiving Seized Documents: ITAT

The Delhi Bench of Income Tax Appellate Tribunal has held that the computation of six assessment years for search assessments under Section 153C of the Income Tax Act starts from the date of receiving seized documents.The bench of Saktijit Dey and Naveen Chandra has relied on the decision of the Supreme Court in the case of CIT vs. Jasjit Singh,. The Delhi Bench of Income Tax Appellate Tribunal has held that the computation of six assessment years for search assessments under Section 153C of the Income Tax Act starts from the date of receiving seized documents. The bench of Saktijit Dey and Naveen Chandra has relied on the decision of the Supreme Court in the case of CIT vs. Jasjit Singh, in which it was held that under Section 153C, a third party would only have to furnish income tax returns for the preceding six years, starting from the date when the Assessing Officer assigns the third party's documents to the concerned Assessing Officer and not from the date of the original search. The tribunal held that the FY 2004–05 would therefore fall beyond the period of six assessment years as reckoned with reference to the date of recording satisfaction by the assessing officer of the searched person.