Section 153C proceedings: undated satisfaction notes make notice date operative for six-year block, assessment for AY 2015-16 quashed.

Proceedings under section 153C raised after a search turned on the availability and dating of satisfaction notes; where satisfaction notes recorded for both the searched party and the non-searched assessee were undated, the date of issuance of the notice under section 153C is the relevant triggering date for computing the six-year assessment block. Applying that rule, the notice dated 10.05.2023 makes the six-year block run from AY 2024-25 back to AY 2018-19; consequently the assessment framed under section 153C for AY 2015-16 is time-barred and quashed.

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Issues: Whether the assessments framed under section 153C of the Income-tax Act, 1961 for A.Y.2015-16 and A.Y.2017-18 are barred by limitation where the satisfaction notes recorded by the assessing officers are undated and the section 153C notice in the assessee's case was issued on 10.05.2023.

Analysis: The statutory scheme for block assessments under section 153C requires identification of the commencement date for reckoning the block of assessment years. Where the satisfaction note or the date of actual handing over of seized material is not available or is undated, the date of issuance of the section 153C notice is the pertinent date for computing the block period. Applying this rule, the notice dated 10.05.2023 fixes the relevant search (deemed) year such that the six-year block commences from A.Y.2024-25 and extends to A.Y.2018-19. The satisfaction notes in the record are undated and there is no evidence of a dated handing over of seized material that would shift the commencement earlier. Consequently, A.Y.2015-16 and A.Y.2017-18 fall outside the six-year block capable of being assessed under section 153C.

Conclusion: The assessments framed under section 153C for A.Y.2015-16 and A.Y.2017-18 are time-barred and are quashed; decision is in favour of the assessee.

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