Section 153C block period runs from receipt of seized material by the Assessing Officer, invalidating time-barred assessments.

In section 153C proceedings for a non-searched person, the ten-year block period is computed from the date the seized books, documents or assets are received by the jurisdictional Assessing Officer, because that receipt date operates as the deemed date of search. On the facts stated, the satisfaction note and handing over of material on 17.02.2022 fixed the reference point, making AY 2023-24 the relevant year; AYs 2011-12 and 2012-13 were therefore outside the permissible block period, and the assessment orders were quashed for want of valid jurisdiction.

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Issues: Whether, for proceedings under section 153C, the ten-year block period is to be computed from the date of receipt of seized material by the jurisdictional Assessing Officer of the non-searched person, and whether the assessment years 2011-12 and 2012-13 fell within the permissible block period.

Analysis: The governing principle is that, for a non-searched person covered by section 153C, the relevant starting point is not the date of search on the third party but the date on which the seized books of account, documents or assets are received by the jurisdictional Assessing Officer. That date operates as the deemed date of search for computing the relevant assessment years. Applying that principle to the facts, the satisfaction note and handing over of material on 17.02.2022 fixed the reference point, from which the relevant assessment year became AY 2023-24. The assessments for AYs 2011-12 and 2012-13 were therefore outside the ten-year block and the Assessing Officer lacked valid jurisdiction.

Conclusion: The assessments for AYs 2011-12 and 2012-13 were invalid as being beyond the block period, and the assessee succeeded on the jurisdictional issue.

Final Conclusion: The assessment orders were quashed for want of valid assumption of jurisdiction under section 153C, and the Revenue's challenge failed.

Ratio Decidendi: In proceedings under section 153C, the block period is computed from the date of receipt of seized material by the jurisdictional Assessing Officer of the non-searched person, which functions as the deemed date of search for that person.

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