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TMI Blog2024 (12) TMI 1068X X X X Extracts X X X X X X X X Extracts X X X X ..... Section 153A and Section 153C - Period of limitation - Nature of the incriminating material that may be obtained and the years forming part of the block which would merit being thrown open As decided by HC [ 2024 (4) TMI 461 - DELHI HIGH COURT] abatement of the six AYs or the relevant assessment year would follow the formation of that opinion and satisfaction in that respect being reached. We come ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to firstly be satisfied that the material received is likely to have a bearing on or impact the total income of years or years which may form part of the block of six or ten AYs and thereafter proceed to place the assessee on notice under Section 153C. The power to undertake such an assessment would stand confined to those years to which the material may relate or is likely to influence. Absent a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... R. JUSTICE R. MAHADEVAN For the Petitioner : Mr. S Dwarakanath, A.S.G. Mr. Rupesh Kumar, Sr. Adv. Mr. Raj Bahadur Yadav, AOR Mr. Gaurang Bhushan, Adv. Mr. Ram Krishna Rao , Adv ORDER UPON hearing the counsel the Court made the following. 1. Heard the learned counsel for the petitioners. 2. There is a delay of 124 and 127 days in filing the Special Leave Petitions respectively, which has not been s ..... X X X X Extracts X X X X X X X X Extracts X X X X
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