Section 153C limitation runs from handover of seized material, making out-of-window assessments without jurisdiction.

For section 153C proceedings, the six-year limitation block is computed from the date the seized material is handed over to the jurisdictional Assessing Officer, as reflected in the satisfaction note. On that basis, assessment years 2013-14 and 2014-15 fell outside the permissible window linked to the later block, so the assumption of jurisdiction was invalid. The consequential assessments were therefore unsustainable and were quashed.

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Issues: Whether the assessment framed under section 153C of the Income-tax Act, 1961 was barred by limitation on the facts of the case and whether the consequential assessments could be sustained.

Analysis: The relevant point of origin for computing the six-year period under section 153C was taken as the date of handing over of the seized material to the jurisdictional Assessing Officer, which was reflected in the satisfaction note dated 18.04.2022. On that basis, the permissible assessment years fell within the later block beginning from assessment year 2023-24, whereas the impugned assessment years 2013-14 and 2014-15 lay outside that six-year span.

Conclusion: The assumption of jurisdiction under section 153C was invalid and the assessments could not be sustained.

Final Conclusion: The appeals succeeded and the impugned assessments were quashed.

Ratio Decidendi: For proceedings under section 153C, the limitation block is to be computed from the date on which the seized material is handed over to the jurisdictional Assessing Officer, and any assessment beyond the statutory six-year window is without jurisdiction.

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