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"River cuts the rock not because of its power but because of its consistency. 
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Important Case Law:

“Time limit for completion of assessment under section 153C is 12 months from end of FY in which search was conducted: HC”

Where assessment proceedings under section 153C were initiated against petitioner, a third party, on basis of search conducted in case of one ORL, since Assessing Officer of searched party as well as third party, i.e. petitioner, was one and same, there was no question of transfer of records seized under section 153C and, thus, time limit provided by first limb of clause (ii) of third proviso to section 153B(1) shall apply, which was 12 months from end of financial year in which search took place

Case Analysis: Vijay Bihari Kandhari v. Assistant Commissioner of Income-tax

Date:                 November 17, 2025

Citation:           [2025] 181 taxmann.com 21 (Bombay)

Bench:              B. P. Colabawalla and Amit S. Jamsandekar, JJ. 

Facts of the Case:

• A search and seizure operation under section 132 was carried out on 21-8-2019 in the case of ORL. In the course of the aforementioned search, some incriminating documents and information concerning the petitioner were discovered and seized by the Income Tax Department. Because of the same, proceedings under section 153C were initiated against the petitioner, resulting in the issuance of the impugned notices under section 153C for assessment years 2014-15 to 2019-20.

• The petitioner filed instant writ petition to quash said proceedings on ground that the time limit for completion of the assessment as per section 153B, read with the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (TOLA), expires on 30-9-2021. It was therefore submitted that the said assessments had not been completed under the said statutory time limit.

For Judgment,  Please click here

Useful Updates:

( Contribution by CA. Rishabh Agarwal )

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• Indirect Tax Updates From 1st November 2025 to 15th November 2025  Read More

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