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2023 (6) TMI 553 - AT - Income TaxAssessment u/s 153C - Reckoning of six years for assessment - whether the assessment year for reassessment u/s 153C are to be reckoned as six years prior to the year in which search has taken place or six years prior to the year in which seized material is received by the AO of the other person? - HELD THAT:- We find in the case of CIT v. RRJ Securities [2015 (11) TMI 19 - DELHI HIGH COURT] has held that for the purpose of section 153C six years has to be reckoned as six years prior to the date of receipt of seized material by the AO of the other person. We hold that in the case of the assessee six years for assessment u/s 153C has to be reckoned are assessment year 2013-14 to assessment year 2018-19. Assessment proceedings in these two years completed u/s 153C are not accordance with law and accordingly we quash the assessment proceedings for AY 2011-12 & 2012-13. Decided against revenue.
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