Section 153C assessments based on seized material transfer date: only six prior AYs count; older AY additions struck down.

The dominant issue was whether an assessment could validly be made under s.153C for an earlier AY beyond the six-year block. The ITAT held that, for the person other than the searched person, the date of recording satisfaction and handing over seized material is the deemed date of search; consequently, proceedings under s.153C can cover only six AYs preceding the year in which such satisfaction is recorded. On that basis, only AYs 2016-17 to 2021-22 were within scope, and the impugned AY (2012-13/2013-14) fell outside s.153C. Relying on binding HC ratios and SC authority, the deletion of the addition was upheld and the Revenue's appeal was dismissed.

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A search and seizure under Section 132 was conducted on 02/11/2017 in another person's case. The Assessing Officer of the searched person recorded satisfaction that certain seized documents "pertaining to the Assessee herein" had a bearing on determination of total income and handed them over to the Assessee's Assessing Officer on 24/06/2021. The Assessee's Assessing Officer recorded satisfaction under Section 153C on 24/06/2021, issued notice under Section 153C, and completed assessment on 31/12/2022 making additions. On appeal, the additions were deleted by applying the settled limitation framework for Section 153C (including precedents such as RRJ Securities, Singhad Technical Education Society, and Ojjus Medicare). The Tribunal held that, for Section 153C, "the date of satisfaction and handing over the seized material would be the deemed date of search" for the other person. Consequently, proceedings can cover only "six Assessment Years from preceding year in which satisfaction was recorded," so notice could extend to AY 2016-17 to 2021-22, not AY 2013-14. As the year in question fell outside Section 153C's permissible period, the deletion was upheld, noting the issue is "not res-integra" and supported by Supreme Court authority in Jasjit Singh.

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