First proviso to section 153C provides that six assessment years in which assessment or reassessments could be made under section 153C would have to be considered with reference to date of handing over of assets or documents to Assessing Officer of other person, i.e., assessee.

ITAT states that, it is not in dispute that search was conducted on 20.01.2014 in the cases of M/s Mapsa Logistics (P) Ltd. & Ors. and satisfaction under section 153C was recorded on 23.02.2016 that the documents pertaining to assessee have been seized during the course of search. The Assessing Officer, accordingly, issued notice under section 153C on 23.02.2016. The issue is, therefore, covered by judgment of Hon’ble Delhi High Court in the case of CIT v. RRJ Securities Ltd. 380 ITR 612 (Del) as is considered by the Ld. CIT(A) in the impugned order. The six assessment years for which assessments/ reassessments could be made under section 153C of the Act would also have to be construed with reference to the date of handing over of the assets/documents to the Assessing Officer of the assessee i.e. 23.02.2016. Therefore, the relevant assessment years for initiating proceedings under section 153C would be assessment years 2010-11 to 2015-16. Therefore, the assessment years under appeal i.e. 2008-09 & 2009-10 would be beyond the period of six years. (Related Assessment Year : 2008-09 & 2009-10) – [ACIT v. Mapsa Tapes (P) Ltd. – Date of Judgement : 21.02.2020 (ITAT Delhi)]