S. 153C : Assessment – Income of any other person – Search – Block period – The period of the “relevant assessment year” is to be calculated, to the date of receipt of the books of accounts, documents or assets seized by the jurisdictional AO of the non-searched person- Block periods would have to be reckoned with reference to the date of search can neither be countenanced nor accepted- Precondition of Rs. 50 lakhs or more constitutes a sine qua non for initiating action for the extended ten-year block, the aforesaid satisfaction and the reasons in support thereof would have to borne out from the satisfaction note itself. [ S.68, 69C, 153A, 260A, Art. 226 ]
PCIT v. Ojjus Medicare Pvt. Ltd& Ors ( Delhi)( HC) www.itatonline .org