Admitting the additional ground of the assessee the Tribunal held that ,  as per the first proviso to Section 153C(1) the date of initiation of search u/s 132 of the Act for the purpose of an assessment u/s 153C has to be construed as the date of receiving the books of account by the A.O. having jurisdiction over such other person, from the A.O. of the searched person.  In case the A.O of the searched person and that of the assessee is the same person, then the date of recording of „satisfaction‟ by the A.O in the file of the assessee i.e the person other than the searched person, shall be taken as the relevant date for reckoning the period of six assessment years for which assessments could have been framed u/s 153C.   In case, the claim of the assessee that the year under consideration vis. A.Y.2007-2008 falls beyond the scope of six assessment years from the aforementioned date of recording of satisfaction or receiving of documents or assets seized or books of accounts by the A.O of the assessee, as the case may be, then the assessment framed by the A.O shall stand vacated  (ITA Nos.83 to 89/Mum/2018  dt 28 -5 -2019 ) (AY.  2007-08 to 2013-2014)

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