Section 153C jurisdiction failed where the relevant year fell outside the six-year block linked to seized material handover.

Section 153C jurisdiction depends on the deemed date of search, which in this text is the date the seized material was handed over, 24.06.2021. The provision reaches only six assessment years preceding the year in which satisfaction is recorded and the material is handed over. On that basis, the permissible block was 2016-17 to 2021-22, while the relevant year fell outside that period. The notice and assessment were therefore without jurisdiction, and the additions were deleted.

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Issues: Whether the assessment and notice issued under section 153C of the Income-tax Act, 1961 for the relevant assessment year were within jurisdiction when the seized material was handed over on 24.06.2021.

Analysis: The seized documents were handed over on 24.06.2021, and that date, for the purpose of section 153C, is treated as the deemed date of search in relation to the assessee. The jurisdiction under section 153C extends only to six assessment years preceding the year in which satisfaction is recorded and the material is handed over. On that basis, the permissible assessment years were 2016-17 to 2021-22, whereas the year under consideration fell outside that block. The issue was already settled in favour of the assessee by binding precedent.

Conclusion: The notice and assessment under section 153C for the relevant year were without jurisdiction, and the deletion of additions was .

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