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2022 (12) TMI 1124 - ITAT DELHIAssessment u/s 153C - Period of limitation - 6 years for the purpose of 153A and 153C - HELD THAT:- As in this case, there was a search conducted on 07.04.2016. AO’s satisfaction for starting 153C proceedings against the present assessee was recorded on 29.03.2019. Taking this into account, six preceding assessment years are 2014-15 to 2019-20 which excludes AYs 2012-13 & 2013-14. This is as per the ratio laid down in the case of CIT vs. RRJ Securities Ltd.. [2015 (11) TMI 19 - DELHI HIGH COURT] and in Karina Airlines International Ltd.[2021 (6) TMI 368 - ITAT DELHI] had held that the amendment brought by the Finance Act, 2017 would not be applicable as it is prospective. It is not the case that Hon’ble High Court has reversed the above decision of ITAT, Hence, following the precedence, we reject the pleadings and submission of the ld. CIT DR for the Revenue. In the present cases, since the date of search was 07.04.2016 the amendment brought by the Finance Act, 2017 would not be applicable. Accordingly, respectfully following the precedent as above, we do not find any infirmity in the order of the ld. CIT (A). Hence we uphold the same. Appeals filed by the Revenue are dismissed.
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