Section 153C jurisdiction turns on the satisfaction-note date and the six-year block for the other person.

For section 153C proceedings, the date of recording satisfaction in the case of the searched person is treated as the date of search for the other person, and the six assessment years must be counted from that date. On that basis, where the relevant assessment year falls outside the permissible six-year block, the assumption of jurisdiction under section 153C cannot be sustained. The assessment was therefore quashed as without jurisdiction.

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Issues: Whether the assessment framed under section 153C of the Income-tax Act, 1961 was without jurisdiction as the relevant assessment year fell beyond the permissible block of six assessment years counted from the date treated as the date of search in the case of the other person.

Analysis: The seized material relating to the assessee was found in a search conducted in the case of the searched person, and the satisfaction note recorded in that case determined the date relevant for initiating proceedings against the other person. On the basis of the binding interpretation of section 153C, the date of recording satisfaction in the case of the searched person is treated as the date of search for the other person, and the six assessment years have to be reckoned accordingly. Since the impugned assessment year was beyond that six-year block, the assumption of jurisdiction under section 153C could not be sustained.

Conclusion: The assessment under section 153C was quashed as being without jurisdiction, and the challenge on this issue succeeded in favour of the assessee.

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