Section 153C jurisdiction depends on the statutory block period from the satisfaction note, making out-of-period proceedings invalid.

A notice under Section 153C must fall within the six assessment years computed from the relevant satisfaction note; where the note was recorded on 28.07.2022, the permissible block did not extend to Assessment Year 2016-17. The extended ten-year period was not applicable on the stated facts, so jurisdiction for that year was beyond the statutory block period. As the foundational notice was invalid, the consequential assessment proceedings and assessment order could not survive and were set aside.

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Issues: Whether a notice issued under Section 153C of the Income Tax Act, 1961 for Assessment Year 2016-17 was sustainable when the relevant satisfaction note was recorded on 28.07.2022 and the six-year block period had already to be reckoned from that date; and whether the consequential assessment proceedings and assessment order could survive.

Issue: Whether the notice issued under Section 153C for Assessment Year 2016-17 was within the permissible six-year block period.

Analysis: The notice under Section 153C had to be tested against the six assessment years relatable to the satisfaction note dated 28.07.2022. On that basis, the covered assessment years extended only up to Assessment Year 2017-18 and did not reach Assessment Year 2016-17. The extended ten-year period was not applicable on the facts. The assumption of jurisdiction for Assessment Year 2016-17 was therefore beyond the statutory block period.

Conclusion: The notice under Section 153C for Assessment Year 2016-17 was unsustainable and is set aside.

Issue: Whether the consequential proceedings, including the assessment order passed pursuant to the notice, could stand.

Analysis: Once the foundational notice was invalid, all proceedings founded upon it could not be sustained.

Conclusion: The consequential proceedings, including the assessment order, are set aside.

Final Conclusion: The challenge succeeded in full and the jurisdictional action based on the impugned notice could not be maintained.

Ratio Decidendi: A notice under Section 153C can sustain only for assessment years falling within the statutory block period computed from the relevant satisfaction note, and proceedings taken beyond that jurisdictional limit are void.

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