Validity of assessments under search and seizure: deemed search date fixes limitation, earlier assessment years held beyond jurisdiction.

Date of recording the satisfaction note in the searched person's files constitutes the deemed date of search for the nonsearched person, so limitation for assessments under the search regime is computed from that date. The article applies settled precedent of the Supreme Court and Delhi High Court holding that receipt of seized documents triggers the deemed search date; here the satisfaction note dated 24.06.2022 makes the relevant search year FY 2022-23 (AY 2023-24). Consequently the tenyear limitation block runs back only to AY 2014-15, rendering AY 2011-12 and 2012-13 beyond jurisdiction and not assessable.

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Issues: Whether the assessments framed under section 153C of the Income-tax Act, 1961 for A.Y. 2011-12 and A.Y. 2012-13 are time-barred because the satisfaction note in respect of the non-searched person (assessee) was recorded on 24.06.2022, thereby making the deemed year of search A.Y. 2023-24 and excluding the impugned assessment years from the ten-year block.

Analysis: The Court examined the effect of the First Proviso to section 153C(1) which deems the commencement date for computing the six-year or ten-year block to be the date of receipt of books of accounts, documents or assets seized from the searched person by the jurisdictional AO of the non-searched person. Relying on the authoritative rulings interpreting section 153C (including the Supreme Court decision in CIT v. Jasjit Singh and subsequent High Court authority), the Court treated the satisfaction note dated 24.06.2022 as the deemed date of search for the assessee, shifting the reference point for limitation to A.Y. 2023-24 and computing the backward ten-year block accordingly.

Conclusion: The assessments framed under section 153C for A.Y. 2011-12 and A.Y. 2012-13 are time-barred and the impugned assessment orders are quashed. The Revenue's appeals are dismissed.

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