Section 153C provisions are inapplicable as notice was issued to 'other person' under this section....

Section 153C provisions are inapplicable as notice was issued to 'other person' under this section. Computation of six-year block period preceding assessment year relevant to previous year of search differs. For 'other person', block period starts from date of notice u/s 153C based on seized documents, not search date. Hence, for AY 2012-13, relevant block period is AY 2007-08 to 2012-13. Notice u/s 153C cannot reopen assessment for AY 2006-07. CIT(A)'s conclusion upheld, dismissing Revenue's appeal on jurisdictional grounds. .....

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