2025 (2) TMI 1439 - AT - Income Tax

Block assessment years determined from search year under Section 153C, AY2014-15 excluded and addition deleted on appeal.

Whether AY 2014-15 falls within the six-year block for assessment under Section 153C was determined by reference to the deemed date of satisfaction ... Validity of assessment u/s 153C - block Assessment Years - scope of the six-year block period in search-originated assessments HELD THAT:- In the present case, the satisfaction has been recorded by the A.O. of the Assessee on 09/02/2022 and the search year for the Assessee would be 2022-23 and the block six years for the assessment u/s 153C would be Assessment Year 2016-17 to 2021-22. Therefore, the year under consideration i.e. Assessment Year 2014-15 will not come under the block Assessment Years. CIT(A) committed no error in deleting the addition by relying on the ratio laid down in the case of RRJ Securities [2015 (11) TMI 19 - DELHI HIGH COURT] and Jagjit Singh [2023 (10) TMI 572 - SUPREME COURT] Appeal of revenue dismissed. Issues: Whether Assessment Year 2014-15 falls within the six block assessment years for the purpose of assessment under Section 153C of the Income-tax Act, 1961, having regard to the deemed date of search/satisfaction recorded on 09/02/2022.Analysis: The material records a satisfaction dated 09/02/2022 which determines the search year as 2022-23. Under the legal framework governing assessments initiated under Section 153C of the Income-tax Act, 1961, the relevant block of six assessment years is computed with reference to the search year. Applying that rule, the six block years for assessment under Section 153C in the present facts are Assessment Years 2016-17 to 2021-22. The Assessment Year 2014-15 therefore lies outside the computed block period. Precedents addressing the scope of block years and the effect of the deemed date of search are applied to assess whether additions framed in the assessment fall within the statutory block period.Conclusion: Assessment Year 2014-15 does not fall within the six block assessment years for assessment under Section 153C of the Income-tax Act, 1961; the appellate authority's deletion of the addition is upheld, and the Revenue's appeal is dismissed (favouring the assessee).