Section 153C limitation and mandatory section 153D approval were decisive; the assessment was annulled for jurisdictional defects.

For assessments under section 153C, the permissible block of assessment years is to be computed from the date of recorded satisfaction; where the relevant year falls beyond the ten-year limit, the assessment is unsustainable in law. The text states that assessment year 2011-12, with satisfaction recorded on 01.02.2022, was beyond the statutory limit and was therefore annulled on limitation grounds. It also states that a common approval under section 153D is a mandatory safeguard; where valid approval is not properly obtained, the defect vitiates the assessment. On that basis, the assessment was also held invalid for want of compliant section 153D approval, and the assessee obtained relief.

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Issues: (i) Whether the assessment framed under section 153C of the Income-tax Act, 1961 for assessment year 2011-12 was barred by limitation having regard to the date of satisfaction and the permissible block of assessment years; (ii) Whether the common approval under section 153D of the Income-tax Act, 1961 validated the assessment.

Issue (i): Whether the assessment framed under section 153C of the Income-tax Act, 1961 for assessment year 2011-12 was barred by limitation having regard to the date of satisfaction and the permissible block of assessment years.

Analysis: The assessment year involved was 2011-12, whereas the satisfaction under section 153C(1) was recorded on 01.02.2022. On that basis, the assessment year fell beyond the maximum period of ten assessment years computed from the relevant satisfaction date. The assessment was therefore found to be beyond the statutory limit governing proceedings under section 153C.

Conclusion: The assessment was held to be unsustainable in law on the ground of limitation, in favour of the assessee.

Issue (ii): Whether the common approval under section 153D of the Income-tax Act, 1961 validated the assessment.

Analysis: The Assessing Officer had obtained a common approval under section 153D on 29.12.2022. The absence of proper compliance with the statutory approval requirement was treated as a defect going to the root of the assessment and rendering it invalid.

Conclusion: The assessment was held to be vitiated for want of valid section 153D approval, in favour of the assessee.

Final Conclusion: The assessment was annulled on jurisdictional and approval-related grounds, and the Revenue's challenge failed while the assessee obtained relief.

Ratio Decidendi: For assessments under section 153C, the permissible assessment years must be computed from the date of satisfaction, and a valid section 153D approval is a mandatory safeguard whose breach vitiates the assessment.

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