In Brief
The Commissioner of Income Tax appealed against High Court orders dismissing its appeals regarding the assessment of third parties whose documents were found during a search of another entity. The key issue was whether the six-year assessment period for such third parties begins from the date of the original search or from when the Assessing Officer receives the materials. The Supreme Court held that the proviso to Section 153C(1) of the Income Tax Act, 1961, establishes that the period runs from the date of receiving the materials—not the search date. This interpretation protects third parties from disproportionate burden and reflects Parliament's protective intent. The appeals were dismissed.
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