CIT v. Calcutta Knitwears

362 ITR 673Supreme Court of India2014#122 most cited

What is CIT v. Calcutta Knitwears authority for?

The recording of a satisfaction note by the Assessing Officer is a jurisdictional prerequisite for assessments under Section 153C, and the six-year limitation period for such assessments is reckoned from the date this satisfaction is recorded.

528

judgments rely on this decision, according to BharatTax’s citation analysis of 367,368 Indian tax judgments — from 2012 to 2026.

Also referred to as

CIT v. Calcutta Knitwears · section 153C · satisfaction note · jurisdictional prerequisite · limitation period · seized material · assessment year · block period · search assessment · section 158BD

Also reported as

43 Taxmann.com 446223 Taxmann 115

Sections most often in play

Section 153CSection 143(3)Section 132Section 153ASection 153DSection 144Section 115BBESection 292C
Read the full judgment

Issues it is cited on

section 158bdincome tax settlement commissionsection 158bcsection 144asection 144basatisfaction notesection 158bblock periodsection 158section 153c(1)documents seizedsection 292c

Judgments citing CIT v. Calcutta Knitwears

Deputy Commissioner of Income Tax(Central Circle), Allahabad vs. Jeevan Jyoti Charitable Trust, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 39/ALLD/2025[2011-12]Status: DisposedITAT Allahabad30 Sept 2025AY 2011-12

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…be given effect of the word in its own terms and there is no scope for importing any rule of interpretation. Learned Departmental Representatives also placed reliance on the precedents in the cases of 438 ITR 288 (SC) CIT vs. Mohammed Meeran Shahul Hameed and 362 ITR 673 (SC) CIT vs. Calcutta Knitwears for the proposition that a provision of the Act is to be read as it is and nothing is to be added or taken away from it. Learned Departmental Representatives placed further reliance on 266 ITR 1 (SC) Prakash Nath Khanna vs CIT and 121 ITR 535 (SC) CIT vs. National Taj Traders for the proposition that casus omissus…

Arpit Hospital Private Limited, Allahabad vs. DCIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 14/ALLD/2025[2013-14]Status: DisposedITAT Allahabad30 Sept 2025AY 2013-14

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…be given effect of the word in its own terms and there is no scope for importing any rule of interpretation. Learned Departmental Representatives also placed reliance on the precedents in the cases of 438 ITR 288 (SC) CIT vs. Mohammed Meeran Shahul Hameed and 362 ITR 673 (SC) CIT vs. Calcutta Knitwears for the proposition that a provision of the Act is to be read as it is and nothing is to be added or taken away from it. Learned Departmental Representatives placed further reliance on 266 ITR 1 (SC) Prakash Nath Khanna vs CIT and 121 ITR 535 (SC) CIT vs. National Taj Traders for the proposition that casus omissus…

Arpit Hospital Private Limited, Allahabad vs. DCIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 13/ALLD/2025[2012-13]Status: DisposedITAT Allahabad30 Sept 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…be given effect of the word in its own terms and there is no scope for importing any rule of interpretation. Learned Departmental Representatives also placed reliance on the precedents in the cases of 438 ITR 288 (SC) CIT vs. Mohammed Meeran Shahul Hameed and 362 ITR 673 (SC) CIT vs. Calcutta Knitwears for the proposition that a provision of the Act is to be read as it is and nothing is to be added or taken away from it. Learned Departmental Representatives placed further reliance on 266 ITR 1 (SC) Prakash Nath Khanna vs CIT and 121 ITR 535 (SC) CIT vs. National Taj Traders for the proposition that casus omissus…

Vandana Bansal L/H of Late Dr. Ashwani Kumar Bansal, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 40/ALLD/2019[2013-14]Status: DisposedITAT Allahabad30 Sept 2025AY 2013-14

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…be given effect of the word in its own terms and there is no scope for importing any rule of interpretation. Learned Departmental Representatives also placed reliance on the precedents in the cases of 438 ITR 288 (SC) CIT vs. Mohammed Meeran Shahul Hameed and 362 ITR 673 (SC) CIT vs. Calcutta Knitwears for the proposition that a provision of the Act is to be read as it is and nothing is to be added or taken away from it. Learned Departmental Representatives placed further reliance on 266 ITR 1 (SC) Prakash Nath Khanna vs CIT and 121 ITR 535 (SC) CIT vs. National Taj Traders for the proposition that casus omissus…

Vandana Bansal L/H of Late Dr. Ashwani Kumar Bansal, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 39/ALLD/2019[2012-13]Status: DisposedITAT Allahabad30 Sept 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…be given effect of the word in its own terms and there is no scope for importing any rule of interpretation. Learned Departmental Representatives also placed reliance on the precedents in the cases of 438 ITR 288 (SC) CIT vs. Mohammed Meeran Shahul Hameed and 362 ITR 673 (SC) CIT vs. Calcutta Knitwears for the proposition that a provision of the Act is to be read as it is and nothing is to be added or taken away from it. Learned Departmental Representatives placed further reliance on 266 ITR 1 (SC) Prakash Nath Khanna vs CIT and 121 ITR 535 (SC) CIT vs. National Taj Traders for the proposition that casus omissus…

Vandana Bansal L/H of Late Dr. Ashwani Kumar Bansal, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 38/ALLD/2019[2011-12]Status: DisposedITAT Allahabad30 Sept 2025AY 2011-12

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…be given effect of the word in its own terms and there is no scope for importing any rule of interpretation. Learned Departmental Representatives also placed reliance on the precedents in the cases of 438 ITR 288 (SC) CIT vs. Mohammed Meeran Shahul Hameed and 362 ITR 673 (SC) CIT vs. Calcutta Knitwears for the proposition that a provision of the Act is to be read as it is and nothing is to be added or taken away from it. Learned Departmental Representatives placed further reliance on 266 ITR 1 (SC) Prakash Nath Khanna vs CIT and 121 ITR 535 (SC) CIT vs. National Taj Traders for the proposition that casus omissus…

Vandana Bansal L/H of Late Dr. Ashwani Kumar Bansal, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 37/ALLD/2019[2010-11]Status: DisposedITAT Allahabad30 Sept 2025AY 2010-11

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…be given effect of the word in its own terms and there is no scope for importing any rule of interpretation. Learned Departmental Representatives also placed reliance on the precedents in the cases of 438 ITR 288 (SC) CIT vs. Mohammed Meeran Shahul Hameed and 362 ITR 673 (SC) CIT vs. Calcutta Knitwears for the proposition that a provision of the Act is to be read as it is and nothing is to be added or taken away from it. Learned Departmental Representatives placed further reliance on 266 ITR 1 (SC) Prakash Nath Khanna vs CIT and 121 ITR 535 (SC) CIT vs. National Taj Traders for the proposition that casus omissus…

Vandana Bansal L/H of Late Dr. Ashwani Kumar Bansal, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 36/ALLD/2019[2009-10]Status: DisposedITAT Allahabad30 Sept 2025AY 2009-10

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…be given effect of the word in its own terms and there is no scope for importing any rule of interpretation. Learned Departmental Representatives also placed reliance on the precedents in the cases of 438 ITR 288 (SC) CIT vs. Mohammed Meeran Shahul Hameed and 362 ITR 673 (SC) CIT vs. Calcutta Knitwears for the proposition that a provision of the Act is to be read as it is and nothing is to be added or taken away from it. Learned Departmental Representatives placed further reliance on 266 ITR 1 (SC) Prakash Nath Khanna vs CIT and 121 ITR 535 (SC) CIT vs. National Taj Traders for the proposition that casus omissus…

Vandana Bansal L/H of Late Dr. Ashwani Kumar Bansal, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 35/ALLD/2019[2008-09]Status: DisposedITAT Allahabad30 Sept 2025AY 2008-09

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…be given effect of the word in its own terms and there is no scope for importing any rule of interpretation. Learned Departmental Representatives also placed reliance on the precedents in the cases of 438 ITR 288 (SC) CIT vs. Mohammed Meeran Shahul Hameed and 362 ITR 673 (SC) CIT vs. Calcutta Knitwears for the proposition that a provision of the Act is to be read as it is and nothing is to be added or taken away from it. Learned Departmental Representatives placed further reliance on 266 ITR 1 (SC) Prakash Nath Khanna vs CIT and 121 ITR 535 (SC) CIT vs. National Taj Traders for the proposition that casus omissus…

Vandana Bansal L/H of Late Dr. Ashwani Kumar Bansal, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 34/ALLD/2019[2007-08]Status: DisposedITAT Allahabad30 Sept 2025AY 2007-08

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…be given effect of the word in its own terms and there is no scope for importing any rule of interpretation. Learned Departmental Representatives also placed reliance on the precedents in the cases of 438 ITR 288 (SC) CIT vs. Mohammed Meeran Shahul Hameed and 362 ITR 673 (SC) CIT vs. Calcutta Knitwears for the proposition that a provision of the Act is to be read as it is and nothing is to be added or taken away from it. Learned Departmental Representatives placed further reliance on 266 ITR 1 (SC) Prakash Nath Khanna vs CIT and 121 ITR 535 (SC) CIT vs. National Taj Traders for the proposition that casus omissus…

Minto Developers Pvt. Ltd., Allahabad vs. Assistant Commissioner of Income Tax, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 337/ALLD/2018[2009-10]Status: DisposedITAT Allahabad30 Sept 2025AY 2009-10

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…be given effect of the word in its own terms and there is no scope for importing any rule of interpretation. Learned Departmental Representatives also placed reliance on the precedents in the cases of 438 ITR 288 (SC) CIT vs. Mohammed Meeran Shahul Hameed and 362 ITR 673 (SC) CIT vs. Calcutta Knitwears for the proposition that a provision of the Act is to be read as it is and nothing is to be added or taken away from it. Learned Departmental Representatives placed further reliance on 266 ITR 1 (SC) Prakash Nath Khanna vs CIT and 121 ITR 535 (SC) CIT vs. National Taj Traders for the proposition that casus omissus…

Alzarafa Travel & Manpower Consultants (P) Ltd, Ernakulam vs. ACIT, Central Circle-2, Kochi

Accordingly, the Assessment Order, dated 05/03/2024, for the Assessment Year 2015-2016 is quashed. Accordingly, Additional Ground No. 1.1 raised by the Assessee vide Letter dated 15/08/2025 is allowed

ITA 575/COCH/2025[2015-16]Status: DisposedITAT Cochin22 Sept 2025AY 2015-16
Section 144Section 153CSection 15CSection 250Section 292B

…## **IN THE INCOME TAX APPELLATE TRIBUNAL "DB" BENCH, COCHIN** ## **SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER ITA No.575/COCH/2025 (Assessment Year:2015-2016)** ## **Al Zarafa Travel & Manpower Consultants (P) Ltd.** Elias George & Co, Chartered Accountants, Hig Avenue, Gandhi Nagar, Kerala- 682020 [PAN: AAFCA4935N] **…………. Appellant** Vs **Assistant Commissioner of Income Tax, Corporate Circle – 2(1), Kochi** CR Building, IS Press Road, Kochi- 682018 **…………. Respondent** #### **Appearance** For the Appellant/Assessee For the Respondent/Department **: :** Shri Thomson…

Mr. Rakesh Sharma, Delhi vs. ACIT, Dehradun

In the result, appeal filed by the assessee in ITA

ITA 40/DDN/2024[2015-16]Status: DisposedITAT Dehradun12 Sept 2025AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 139(1)Section 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN BENCH: DEHRADUN BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA No.39/DDN/2024 (ASSESSMENT YEAR 2013-14) ACIT, Mr. Rakesh Sharma, Central Circle, F-3/12, Basement, Vs. Dehradun. Vasant Vihar, New Delhi-110057. PAN-AYWPS9244C (Appellant) (Respondent) Assessee by Shri S. Krisha, Adv. & Shri Harisht Chouhan, Adv. Department by Sh. S.K. Chatterjee, CIT-DR Date of Hearing 07/08/2025 Date of Pronouncement 12/09/2025 O R D E R PER MANISH AGARWAL, AM: These three appeals are filed by the Assessee for Assessment Years 2012-13,…

Mr. Rakesh Sharma, Delhi vs. ACIT, Dehradun

In the result, appeal filed by the assessee in ITA

ITA 39/DDN/2024[2013-14]Status: DisposedITAT Dehradun12 Sept 2025AY 2013-14

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 139(1)Section 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN BENCH: DEHRADUN BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA No.39/DDN/2024 (ASSESSMENT YEAR 2013-14) ACIT, Mr. Rakesh Sharma, Central Circle, F-3/12, Basement, Vs. Dehradun. Vasant Vihar, New Delhi-110057. PAN-AYWPS9244C (Appellant) (Respondent) Assessee by Shri S. Krisha, Adv. & Shri Harisht Chouhan, Adv. Department by Sh. S.K. Chatterjee, CIT-DR Date of Hearing 07/08/2025 Date of Pronouncement 12/09/2025 O R D E R PER MANISH AGARWAL, AM: These three appeals are filed by the Assessee for Assessment Years 2012-13,…

Mr. Rakesh Sharma, Delhi vs. ACIT, Dehradun

In the result, appeal filed by the assessee in ITA

ITA 38/DDN/2024[2012-13]Status: DisposedITAT Dehradun12 Sept 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 139(1)Section 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN BENCH: DEHRADUN BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA No.39/DDN/2024 (ASSESSMENT YEAR 2013-14) ACIT, Mr. Rakesh Sharma, Central Circle, F-3/12, Basement, Vs. Dehradun. Vasant Vihar, New Delhi-110057. PAN-AYWPS9244C (Appellant) (Respondent) Assessee by Shri S. Krisha, Adv. & Shri Harisht Chouhan, Adv. Department by Sh. S.K. Chatterjee, CIT-DR Date of Hearing 07/08/2025 Date of Pronouncement 12/09/2025 O R D E R PER MANISH AGARWAL, AM: These three appeals are filed by the Assessee for Assessment Years 2012-13,…

Commissioner of Income Tax, Central III, Kolkata vs. Krishna Kumar Daga

ITA/104/2011HC Calcutta20 Aug 2025

Bench: The Tribunal As Well As Before The Lower Authorities Making The Said Order Perverse In Nature”

For Appellant: Mr. Tilak Mitra, AdvocateFor Respondent: Mr. J.P. Khaitan, Senior Advocate
Section 158Section 158BSection 260A

…sion Bench in the case of Commissioner of Income-Tax vs. Bharat Bhushan Jain, (2015) 370 ITR 695 (Delhi), wherein the Hon’ble Division Bench took note of the decision of Supreme Court in the case of Commissioner of Income-Tax vs. Calcutta Knitwears, (2014) 362 ITR 673 (SC) and held that the revenue has to be vigilant in issuing notice to third party under Section 158BD, immediately after completion of assessment of the searched person and the delay ranging between ten months of one and half years cannot be considered contemporaneous to assessment proceedings and therefore held the notices impugned therein…

Sandeep Kumar Agarwal, New Delhi vs. DCIT, Central Circle-7, New Delhi

Appeal is dismissed

ITA 300/DEL/2023[2016-17]Status: DisposedITAT Delhi07 Jul 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2016-17 Vs. Dcit, Sh. Sandeep Kumar Agarwal, 1135, Chatta Madan Gopal, Central Circle-7, Maliwara, Chandni Chowk, New Delhi New Delhi Pan: Agtpa3365R (Appellant) (Respondent) Assessee By Sh. Manju Goel, Ca Department By Sh. Mahesh Kumar, Cit(Dr) Date Of Hearing 07.07.2025 Date Of Pronouncement 07.07.2025 Order Per Satbeer Singh Godara, Jm This Assessee’S Appeal For Assessment Year 2016-17, Arises Against The Commissioner Of Income Tax (Appeals)-24 [In Short, The “Cit(A)”], Delhi’S Order Dated 14.12.2022 Passed In Case No. Cit(A), Delhi-24/10751/2015-16, Involving Proceedings Under Section 153C R.W.S. 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). Heard Both The Parties. Case File Perused. 2. This Assessee’S Appeal Raises The Following Substantive Grounds:

Section 143(2)Section 153ASection 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘G’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER Assessment Year: 2016-17 Vs. DCIT, Sh. Sandeep Kumar Agarwal, 1135, Chatta Madan Gopal, Central Circle-7, Maliwara, Chandni Chowk, New Delhi New Delhi PAN: AGTPA3365R (Appellant) (Respondent) Assessee by Sh. Manju Goel, CA Department by Sh. Mahesh Kumar, CIT(DR) Date of hearing 07.07.2025 Date of pronouncement 07.07.2025 ORDER PER SATBEER SINGH GODARA, JM This assessee’s appeal for assessment year 2016-17, arises against the Commissioner of Income Tax (App…

Smt.Prema Devi, L/R of Late.Shri. Dharmichand, Chennai vs. DCIT, Chennai

ITA 567/CHNY/2023[2012-13]Status: DisposedITAT Chennai27 Jun 2025AY 2012-13

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.: 563 To 567/Chny/2023 निर्धारण वर्ष / Assessment Years: 2008-09 To 2012-13

For Appellant: Shri. D. Anand, AdvocateFor Respondent: Ms. E. Pavuna Sundari, C.I.T
Section 153CSection 153D

…AO of the "other person", as the case may be) is the triggering event, and the six-year time window under Section 153A becomes operative only from that point onward.” 15. The Id.AR further submitted that in the landmark case CIT v. Calcutta Knitwears [(2014) 362 ITR 673 (SC)], the Hon'ble Supreme Court authoritatively held that the recording of satisfaction is a jurisdictional prerequisite u/s.153C of the Act, and that the relevant date for reckoning limitation is the date on which such satisfaction is recorded: “The AO must be satisfied that the seized material pertains to such other person... The period of six…

Smt.Prema Devi, L/R of Late.Shri. Dharmichand, Chennai vs. DCIT, Chennai

ITA 565/CHNY/2023[2010-11]Status: DisposedITAT Chennai27 Jun 2025AY 2010-11

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.: 563 To 567/Chny/2023 निर्धारण वर्ष / Assessment Years: 2008-09 To 2012-13 Smt. Prema Devi, L/R. Of Late. Shri. Dharmichand Jain, No.37, Arumuga Achari Street, Triplicane, Chennai – 600 005. [Pan:Avspp-5090-L] (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement Per S. R. Raghunatha, Am: Vs. The Deputy Commissioner Of Income Tax, Central Circle 2(1), Chennai - 600 034. (प्रत्यर्थी/Respondent) Shri. D. Anand, Advocate Ms. E. Pavuna Sundari, C.I.T. 05.05.2025 27.06.2025 आदेश /Order These Five Appeals Filed By The Assessee Are Directed Against The Common Order Passed By The Learned Commissioner Of Income Tax (Appeals)-19, Chennai, Dated 14.02.2023 & Pertains To Assessment Years 2008-09 To 2012-13. Since, Facts Are Identical & Issues Are Common, For The Sake Of Convenience, The Appeals Filed By The Assessee Are Being Heard Together & Disposed Off, By This Consolidated Order. :-2-:

Section 153CSection 153D

…AO of the "other person", as the case may be) is the triggering event, and the six-year time window under Section 153A becomes operative only from that point onward." 15. The Id.AR further submitted that in the landmark case CIT v. Calcutta Knitwears [(2014) 362 ITR 673 (SC)], the Hon'ble Supreme Court authoritatively held that the recording of satisfaction is a jurisdictional prerequisite u/s.153C of the Act, and that the relevant date for reckoning limitation is the date on which such satisfaction is recorded: “The AO must be satisfied that the seized material pertains to such other person... The period of six…

Smt.Prema Devi, L/R of Late.Shri. Dharmichand, Chennai vs. DCIT, Chennai

In the result all the five appeals of the assessee for the A

ITA 564/CHNY/2023[2009-10]Status: DisposedITAT Chennai27 Jun 2025AY 2009-10

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.: 563 To 567/Chny/2023 िनधा"रण वष" / Assessment Years: 2008-09 To 2012-13 Smt. Prema Devi, The Deputy Commissioner Of L/R. Of Late. Shri. Dharmichand Jain, Vs. Income Tax, No.37, Arumuga Achari Street, Central Circle 2(1), Triplicane, Chennai – 600 005. Chennai – 600 034. [Pan:Avspp-5090-L] (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri. D. Anand, AdvocateFor Respondent: Ms. E. Pavuna Sundari, C.I.T
Section 153CSection 153D

…AO of the "other person", as the case may be) is the triggering event, and the six-year time window under Section 153A becomes operative only from that point onward.” 15. The ld.AR further submitted that in the landmark case CIT v. Calcutta Knitwears [(2014) 362 ITR 673 (SC)], the Hon’ble Supreme Court authoritatively held that the recording of satisfaction is a jurisdictional prerequisite u/s.153C of the Act, and that the relevant date for reckoning limitation is the date on which such satisfaction is recorded: “The AO must be satisfied that the seized material pertains to such other person... The period of six…