Block assessment period under Section 153C: compute six-year block from date satisfaction recorded; appeal dismissed.

Computation of the six-year block for assessments under Section 153C must be measured from the date the assessing officer records satisfaction, not from the date of receipt of seized materials or the earlier search date; accordingly, where satisfaction was recorded on 20.09.2018 the six block assessment years run to AY 2018-19 and do not include AY 2012-13. Applying precedent from higher courts, the tribunal upheld that AY 2012-13 fell outside the six-year block and therefore deleted the addition; the revenue's appeal was dismissed.

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Issues: Whether the six assessment years block for proceedings under Section 153C of the Income-tax Act, 1961 is to be computed with reference to the date of recording of satisfaction/handing over of seized materials to the AO of the non-searched person (date of recording of satisfaction) or from the date of initiation of search.

Analysis: The appellate authority applied judicial precedents which interpret the proviso to Section 153C(1) as requiring the relevant period for computing the six assessment years to be reckoned from the date on which the books, documents or assets belonging to the non-searched person are handed over/when satisfaction is recorded by the AO (the date treated as the 'date of search' for that person), and not from the date of initiation of the original search on another person. This interpretation prevents disproportionate prejudice to the non-searched person by avoiding a retrospective extension of the block period due to delay in forwarding seized materials. The tribunal agreed with the first appellate authority's application of these decisions to the facts where satisfaction was recorded on 20.09.2018, and the searched event occurred earlier; it also noted that the search pre-dated the Finance Act, 2017 amendment and that the cited authorities govern computation in such circumstances.

Conclusion: The six assessment years block under Section 153C is to be computed with reference to the date of recording of satisfaction/handing over of seized materials to the AO of the non-searched person (i.e., the date treated as the date of search for that person). Applying that rule, the assessment year in question falls outside the six-year block and the addition is deleted; the revenue's appeal is dismissed.

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