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of <h1>Tax Notice Invalidated: Section 153C Jurisdictional Limits Protect Taxpayer Rights Beyond Six-Year Assessment Block</h1> <h3>Shri Hari Om Prakash Gupta Versus ACIT Central Circle-28, Delhi</h3> Shri Hari Om Prakash Gupta Versus ACIT Central Circle-28, Delhi - 2025:DHC:3929 - DB The Delhi High Court, through Justice Vibhu Bakhrru (oral judgment), quashed a notice dated 29.07.2022 issued under Section 153C of the Income Tax Act, 1961, relating to AY 2016-17. The notice was based on incriminating material found during a search under Section 132 on 18.10.2019, and subsequent satisfaction notes dated 01.06.2022 and 28.07.2022 by the Assessing Officer (AO). The Court emphasized that the six-year block period for reopening assessments under Section 153C(1)(b) must be reckoned from the date of satisfaction (28.07.2022), covering AY 2017-18 to AY 2022-23. Since AY 2016-17 falls outside this block period and the extended ten-year period was not applicable, the AO's jurisdiction to reopen AY 2016-17 was 'not sustainable.' The Court relied on its precedent in Principal Commissioner of Income Tax-Central-1 v. Ojjus Medicare Pvt. Ltd. (2024 SCC OnLine Del 2439) to support this conclusion. Accordingly, the impugned notice and all subsequent proceedings, including the assessment order, were set aside. The Court's interim order preventing adverse action pending hearing remains operative.
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