Limitation for non-searched persons under section 153C runs from satisfaction recording, rendering the assessments invalid here.

For a non-searched person, the six- or ten-assessment-year period under section 153C is reckoned from the date the Assessing Officer records satisfaction for that person. Applying that jurisdictional rule, and following the earlier binding decision on the same factual matrix, the relevant assessment years fell outside the permissible block period. The assessments were therefore made without valid assumption of jurisdiction and were invalid as time-barred.

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Issues: Whether the assessments for Assessment Years 2011-12 and 2012-13 were invalid for having been made beyond the permissible block period of 10 assessment years under section 153C of the Income-tax Act, 1961.

Analysis: The assessments were examined in the light of the jurisdictional rule that, for a non-searched person, the period of six or ten assessment years is to be reckoned with reference to the date of recording of satisfaction by the Assessing Officer of the non-searched person. Applying the earlier binding decision on the same factual matrix, the relevant assessment years fell beyond the permissible period and the assessments were found to have been made without valid assumption of jurisdiction.

Conclusion: The assessments for both assessment years were held to be invalid as time-barred beyond the block period under section 153C.

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