Bajrang Engineers Private Limited, ... vs Acit,Central Circle, Sambalpur on 7 June, 2022
14. Careful perusal of the language employed in section 153C
makes it clear that in so far as a third party is concerned, the
Legislature has not provided for making the assessments for all
six years, in other words, based upon seized material the
Assessing Officer has to record his satisfaction that the books
of account/documents seized or requisitioned have a bearing
on determination of total income of such other person for the
relevant assessment year. Further similar view has also been
taken by the Tribunal in Trishul Hi-tech Industries Vs. Dy.CIT (in
IT(SS) Nos.82,84-86/Kol/2011 dated 24.9.2014), where the
years involved were A.Ys.200405 to 2006-07, explaining the
amendment to section 153C by Finance (No.2) Act, 2014 to be
clarificatory and thus, retrospective.