153C notice to 'other person' - block period starts from notice date, not search. For AY 2012-13, relevant is AY 2007-08 to 2012-13. Can't reopen AY 2006-07.

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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