S. 153C : Assessment – Income of any other person – Search – Provision applicable to searches conducted prior to date of amendment – (Prior to and after amendment by Finance Act, 2015, with Effect From 1-6-2015)-Search conducted prior to amendment with effect from 1-6-2015 – Books received by Assessing Officer of assessee after that date -Belongs or belong to – Deeming fiction that date of initiation of search would be date when Assessing Officer of third person receives seized material -Amended provision applicable -Interpretation of taxing statutes -Interpretation which effectuates object and purpose of statute preferred.-Amendment by substitution —Rule against retrospectivity. [S. 132]
ITO v. Vikram Sujitkumar Bhatia (2023) 453 ITR 417/ 293 Taxman 4 / 332 CTR 1 / 224 DTR 217 (SC) Editorial: Anil Kumar Gopikrishna Agarwal v.ACIT (2019) 418 ITR 25 /(2020) 186 DTR 273 / 313 CTR 520 (Guj)(HC), reversed.