PCIT v. Karina Airlines International Ltd [2024] 165 taxmann.com 421 / (2025) 474 ITR 340 (Delhi)(HC)

S. 153C : Assessment-Limitation-Finance Act, 2017 amendment-Extension of period from six to ten years-Applicability only when search made on or after 1 4 2017. [S. 132(1), 153A, 153D, Art. 226]

The Finance Act, 2017 extended the block period for search assessments to ten assessment years by introducing “relevant assessment years”. However, the extension applies only where the search occurred on or after April 1, 2017. The date on which the Assessing Officer records satisfaction for the searched and non‑searched persons is material for limitation calculations. Where the search took place on April 7, 2016 (prior to the amendment), the ten‑year extension did not apply and the assessment under section 153C was barred by limitation. (AY.  2012‑13)