Assumption of jurisdiction under s.153C in tax proceedings found time-barred where requisition date places assessments beyond limitation.

Assumption of jurisdiction under s.153C was assessed against the limitation period, with the date of receipt of seized material by the non-searched person determining time bar; consequence: assessments for the specified years were found outside the limitation period and thus barred. The validity of the satisfaction note was challenged as vague and non-descriptive, lacking attribution of incriminating material to particular assessment years, and therefore did not support assumption of jurisdiction under s.153C; consequence: jurisdictional foundation was invalidated. Additions treating share capital and share premium as unexplained were rendered moot because the underpinning assessments were non-maintainable.

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Issues: (i) Whether assessment orders for AYs 2010-11 and 2011-12 framed under section 153C of the Income-tax Act, 1961 are barred by limitation; (ii) Whether the 'Satisfaction Note' relied upon to assume jurisdiction under section 153C for AYs 2012-13 to 2015-16 is legally valid or is vague and non-descriptive so as to vitiate the assessments.

Issue (i): Whether assessment orders for AYs 2010-11 and 2011-12 framed under section 153C are barred by limitation.

Analysis: The Court examined the timing of the 'Satisfaction Note' and the date on which the Assessing Officer of the non-searched person received the seized books/documents and 'Satisfaction Note'. The limitation period applicable to section 153C was considered with reference to the year in which the AO of the assessee received the seized material and the 'Satisfaction Note', and not solely the date of search. The Court applied precedent and coordinate-bench reasoning addressing computation of the six-year limitation period and its interplay with amendments affecting extended limitation baskets.

Conclusion: The assessments for AYs 2010-11 and 2011-12 framed under section 153C are barred by limitation and are quashed in favour of the assessee.

Issue (ii): Whether the 'Satisfaction Note' is legally sufficient and identifies incriminating material year-wise for AYs 2012-13 to 2015-16.

Analysis: The Court reviewed the contents of the 'Satisfaction Note' and whether it identifies incriminating material or undisclosed income attributable to specific assessment years. The judgment considered authorities emphasizing that jurisdiction under section 153C requires identification of material linking undisclosed income to particular years, and that a generic or composite satisfaction without year-wise attribution is legally unsustainable.

Conclusion: The 'Satisfaction Note' is vague and non-descriptive and does not sustain assumption of jurisdiction under section 153C for AYs 2012-13 to 2015-16; the assessments are therefore invalid and allowed in favour of the assessee.

Final Conclusion: The appeals filed by the assessee for AYs 2010-11 to 2015-16 are allowed on grounds of limitation and insufficiency of the 'Satisfaction Note'; the Revenue's appeal challenging additions for AY 2010-11 is dismissed as the underlying assessment is non-est and therefore the merits of additions are academic.

Ratio Decidendi: For the purpose of section 153C, limitation is to be computed from the date the AO of the non-searched person receives the seized books/documents and the 'Satisfaction Note', and a 'Satisfaction Note' that does not identify incriminating material attributable to specific assessment years cannot support jurisdiction under section 153C.

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