Section 153C applies equally to all non-searched entities, ...

Non-searched entities u/s 153C don't require separate regime if AOs are same. Proviso regulates assessment year.

Case Laws     Income Tax

August 6, 2024

Section 153C applies equally to all non-searched entities, without creating a separate regime where the AO of the searched and non-searched entity are the same. The First Proviso to Section 153C(1) regulates the date from which the six-year period or the "relevant assessment year" for the non-searched entity is reckoned. The material unearthed during the search must be independently evaluated to determine if it impacts the total income of the non-searched person. The satisfaction arrived at u/s 153C is the cornerstone for initiating proceedings. The physical transmission of documents is merely a step to enable the AO to examine whether an assessment u/s 153C is liable to be initiated. In cases with a common AO, the commencement point would be the date when the AO forms satisfaction regarding the non-searched entity, even without an actual exchange of material between separate authorities.

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