Section 153C limitation counted from receipt of seized material, barring proceedings for assessment year 2011-12.

Section 153C requires the six-year limitation to be counted from the date the seized material is received by the Assessing Officer of the other person. Where the satisfaction note was recorded on 18.12.2017, the permissible assessment years ran from 2012-13 to 2017-18. Assessment year 2011-12 fell outside that statutory window, so the Assessing Officer lacked jurisdiction to assume proceedings for that year. The section 153C proceedings were therefore not maintainable for assessment year 2011-12, and the assessment order was set aside.

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Issues: Whether the assessment year 2011-12 could be brought within the scope of proceedings under section 153C of the Income-tax Act, 1961 when the satisfaction note was recorded on 18.12.2017.

Analysis: The first proviso to section 153C(1) requires the relevant date for computing the six-year period to be the date on which the seized books, documents or assets are received by the Assessing Officer having jurisdiction over the other person. On the facts, the satisfaction note was recorded on 18.12.2017, making the relevant search year 2018-19 and the permissible six assessment years 2012-13 to 2017-18. Assessment year 2011-12 therefore fell outside the statutory window. In view of the Supreme Court's interpretation of section 153C, the Assessing Officer lacked jurisdiction to make assessment or reassessment for that year.

Conclusion: The proceedings under section 153C were not maintainable for assessment year 2011-12 and the assessment order was set aside, resulting in relief to the assessee.

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