Summary
- The Delhi ITAT has quashed assessments under Section 153C for Genins India Insurance TPA Ltd. due to the deemed search date falling after April 1, 2021.
- The Tribunal ruled that the date seized material was handed over to the jurisdictional AO determines the deemed date of search, which in this case was after the statutory cutoff.
- Consequently, all seven assessment years from AY 2014-15 to AY 2020-21 were invalidated as notices under Section 153C could not be issued post-April 2021.
- This ruling highlights a critical limitation in the assessment process, prompting a need for the Department to explore reassessment under different provisions.
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