Validity of income tax notices under section 153C limited to six years from the financial year before recorded satisfaction, appeals disposed accordingly

Notices issued under the income-tax assessment regime that rely on material seized from third-party premises must be issued within six years from the end of the financial year preceding the date the satisfaction was recorded; notices served beyond that six-year period are invalid. The decision applies the prior ruling in Jasjit Singh and directs disposal of the appeals accordingly, confirming the temporal limit on issuance of such assessment notices and extinguishing notices that exceed that limitation.

---

---

Issues Involved: Validity of notices under Section 153C of the Income Tax Act, 1961.

The Supreme Court, comprising Hon'ble Mr. Justice Sanjiv Khanna and Hon'ble Mr. Justice Dipankar Datta, granted leave in SLP(C) no. 20504/2023 and disposed of the appeals in line with the decision in Commissioner of Income Tax 14 vs. Jasjit Singh [2023] 458 ITR 437. The Court held that notices under Section 153C of the Income Tax Act, 1961 would be valid for a period of six years from the end of the financial year preceding the date on which the satisfaction was recorded. The judgment reiterated the importance of adhering to the statutory provisions and timelines under the Income Tax Act to ensure the validity and enforceability of notices. The Court's decision provided clarity on the timeline within which such notices remain valid, thus setting a precedent for future cases involving similar issues. Any pending applications were also deemed disposed of in light of the judgment, emphasizing the finality and conclusiveness of the Court's decision in the matter.

---