In Brief
The Supreme Court held that the 2015 amendment to Section 153C of the Income Tax Act, which substituted "belongs or belong to" with "pertains or pertain to," applies to searches conducted before the amendment date (01.06.2015). The court rejected the High Court's view that the amendment was merely procedural but affected substantive rights. It reasoned that the amendment was curative, intended to remedy a restrictive judicial interpretation that prevented assessment of third parties when incriminating documents relating to them were found during searches. The proviso to Section 153C deems the relevant date as when the Assessing Officer receives the seized materials—post-amendment in these cases. The court emphasized that machinery provisions must be interpreted to effectuate legislative purpose, not defeat it.
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