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2023 (8) TMI 1181 - AT - Income TaxAssessment u/s 153C - assessment in the case of the 'other person' - period of limitation - CIT(A) quashing the assessment order passed by the AO holding it to be barred by limitation holding that assessment made for assessment year 2014-15 is invalid as 6 previous assessment years from the year of search has to be reckoned from the date when the books of accounts or seized documents were handed over to the Assessing Officer has elapsed - HELD THAT:- Ld. CIT(A) has merely taken into consideration the settled proposition of law of Jurisdictional High Court in the case of CIT vs. RRJ Securities[2015 (11) TMI 19 - DELHI HIGH COURT] to give relief to the assessee and ld. DR could not bring anything to show how there was error in applying the law laid in (Supra). Also in Pr. Commissioner Of Income Tax v. Sarwar Agency Pvt. Ltd. [2017 (8) TMI 733 - DELHI HIGH COURT] Hon’ble Delhi High Court has reaffirmed the law laid in RRJ Securities Case ( Supra) as held in the case of the 'other person' the AO issues notice only subsequent to the notices issued under Section 153 A to the searched person, the starting point for computation of the block period would be the date on which, based on the seized documents, notice is issued to the 'other person' under Section 153C - Decided in favour of assessee.
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