Where search under section 132 was conducted on 10-11-2020 in the case of another person and documents/materials relating to the assessee (being the “other person”) were collected by the Assessing Officer having jurisdiction over the assessee on 30-6-2022, the assessee contended that limitation should be computed from the date of issuance of show-cause notice dated 30-12-2024 and therefore proceedings were time-barred. Dismissing the writ petition, the Court held that as per the first proviso to section 153C(1), in the case of an “other person”, the reference to the date of initiation of search under section 132 or requisition under section 132A has to be construed as the date on which books of account, documents or assets seized are received by the Assessing Officer having jurisdiction over such other person. Since the search was not conducted in the assessee’s premises and materials were received only on 30-6-2022, the limitation period of six years had to be computed from that date and not from the date of show-cause notice; consequently, the notice issued on 30-12-2024 was within limitation. Issues on merits were left open to be agitated before the Assessing Officer in accordance with law. (AY. 2017-18)