Third-party assessment jurisdiction under seized material turns on receipt date, making a non-153C assessment void.

Jurisdiction for a third-party assessment based on seized material is linked to the date the material is received by the Assessing Officer of the other person, and the six-year period under section 153C runs from that date. On the stated facts, the seized cash and related material were handed over on 16.03.2021, falling in the next previous year, so assessment for assessment year 2020-21 could not validly proceed under section 143(3) without a notice under section 153C. The note states that this was a jurisdictional error, rendering the assessment invalid and making the remaining grounds academic.

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Issues: Whether the assessment for the relevant year could validly be framed under section 143(3) of the Income-tax Act, 1961 instead of section 153C, when the seized material was handed over to the Assessing Officer in the following financial year and no notice under section 153C was issued for that year.

Analysis: The jurisdiction under section 153C is attracted with reference to the date on which the books of account, documents or assets are received by the Assessing Officer having jurisdiction over the other person. On the admitted facts, the seized cash and connected material were handed over on 16.03.2021, which fell in the previous year relevant to assessment year 2021-22. The six-year block under section 153C had therefore to be reckoned from that date. In that situation, proceeding with assessment for assessment year 2020-21 under section 143(3), without issuing notice under section 153C, amounted to a jurisdictional error. Once the assessment itself was without jurisdiction, the addition and remaining grounds did not survive for adjudication.

Conclusion: The assessment framed under section 143(3) for assessment year 2020-21 was invalid and was quashed.

Final Conclusion: The assessee succeeded on the jurisdictional issue, the impugned assessment was set aside, and the other grounds became academic.

Ratio Decidendi: For a third-party assessment based on seized material, the relevant six-year period and the assumption of jurisdiction under section 153C are to be determined from the date the material is received by the Assessing Officer of the other person, and an assessment made for a different year without notice under section 153C is void.

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