Ankit Agarwal -Legal Heir of Late Shanti Kumar Aggarwal v. Assistant Commissioner of Income Tax Central Circle 27, Delhi & Anr.
Case brief
What is this about?
The High Court held that for reassessment under Section 153C, the six-year limitation block commences from the date of handing over seized documents to the Assessing Officer of the non-searched person, not the date of search. The INR 50 lakh threshold can be met in aggregate across relevant years without distorting the statute's uniform restriction. The Court ruled that 'finality' of pre-2017 assessments does not bar reopening under these special provisions, which override general reassessment time limits. Petitions challenging notices beyond the ten-year block were allowed.
What did the court decide?
Writ petitions in Lists I and II allowed; notices quashed for AYs 2010-11 to 2013-14. Writs in List III allowed; notice quashed for AY 2016-17 subject to liberty for AO to re-examine the INR 50 lakh threshold. ITA 52/2024 dismissed.