Section 153C time limit bars initiation where the satisfaction note is recorded after the six-year window expires.

Proceedings under Section 153C of the Income-tax Act can be initiated only within six years from the end of the financial year preceding the date on which satisfaction is recorded. Where the satisfaction note was recorded on 02.02.2015, Assessment Year 2007-08 fell outside that six-year span, so initiation and assessment under Section 153C were held not permissible. The challenge to the proceedings therefore failed and the appeal was dismissed.

---

---

Issues: Whether proceedings under Section 153C of the Income-tax Act, 1961 could be initiated for Assessment Year 2007-08 when the satisfaction note was recorded on 02.02.2015 and the six-year period had expired.

Analysis: The satisfaction for initiation of proceedings under Section 153C was recorded on 02.02.2015. On that basis, proceedings could be initiated only for six years from the end of the financial year preceding the date of recording of satisfaction. Since the proposed assessment year fell beyond that period, initiation and assessment under Section 153C were not permissible.

Conclusion: The challenge to the initiation of proceedings under Section 153C failed, and the appeal was dismissed.

---