Deemed Date of Search governs the ten-year block; assessment beyond that block is time barred and quashed.

Deemed date of search (taken as date of notice where no satisfaction note exists) governs computation of the ten-year assessment block; applying that rule fixed the deemed year in F.Y. 2022-23, so assessments prior to A.Y. 2014-15 fall outside the block and are time barred, resulting in quashing of the A.Y. 2012-13 assessment. Separately, appeals for A.Ys. 2019-20 to 2021-22 were rendered academic because remand or fresh assessments produced no adverse additions or disallowances; those appeals are dismissed as infructuous.

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Issues: (i) Whether the assessment framed under the special search provisions was time-barred for A.Y. 2012-13 and thus liable to be quashed for want of jurisdiction; (ii) Whether the appeals against assessments for A.Ys. 2019-20 to 2021-22 are maintainable where subsequent assessments rendered them infructuous.

Issue (i): Validity of assessment framed under special search provisions for A.Y. 2012-13 being beyond the block of ten assessment years.

Analysis: The deemed commencement date for computing the ten-year block is the date on which books/documents/assets of the non-searched person are received by the jurisdictional assessing officer or the date satisfaction is recorded; absence of a satisfaction note on record led to treating the date of issuance of notice under the special provision as the deemed date of satisfaction. Applying the settled principles in the cited precedents, the deemed year of search was determined as F.Y. 2022-23 (A.Y. 2023-24) and counting ten years backwards confines the block to A.Y. 2014-15 onwards, excluding A.Y. 2012-13.

Conclusion: The assessment for A.Y. 2012-13 is time barred and is quashed in favour of the assessee.

Issue (ii): Consequence of subsequent assessment proceedings for A.Ys. 2019-20 to 2021-22 where remand or fresh assessments produced no adverse additions.

Analysis: The appellate orders had remitted the matters to the assessing officer and subsequent effect-giving assessments resulted in no additions or disallowances prejudicial to the assessee, thereby rendering the appeals academic.

Conclusion: The appeals for A.Ys. 2019-20 to 2021-22 are dismissed as infructuous.

Final Conclusion: The appeals are partly allowed insofar as A.Y. 2012-13 is concerned (assessment quashed as time barred) and the appeals relating to A.Ys. 2019-20 to 2021-22 are dismissed as infructuous.

Ratio Decidendi: Where satisfaction for a non-searched person is recorded (or the date of notice is treated as the deemed date in absence of a satisfaction note), the deemed date of search governs computation of the ten-year block and a notice or assessment outside that block is time barred and subject to quashing for want of jurisdiction.

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