CIT v. Jasjit Singh (2025) 476 ITR 157 /304 Taxman 602 (SC) Editorial : CIT v. Jasjit Singh (2023) 458 ITR 437 / 295 Taxman 612/ 334 ITR 937 (SC), reaffirmed. Refer, CIT v. Jasjit Singh (2023) 155 taxmann.com 154 (Delhi)(HC)

S. 153C : Assessment-Income of any other person-Search-
Period of six years-Commences from date materials forwarded-to review petition dismissed due to delay of 433 days and also on merits. [S. 153A, Art. 136]

On a review petition against the decision of the court to the effect that under section 153C of the Income-tax Act, 1961, the period of six-years in respect of which returns are to be filed by the third-party assessee (i.e., other than the assessee in respect of whom the search was conducted) commences only from the date the materials are forwarded to the Assessing Officer of the third-party assessee.  SLP dismissed on account of delay of   433 days in filing the review petition had not been satisfactorily explained  and also  on the merits.(AY. 2009-10, 2010-11)

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