2026 (3) TMI 1502 - SCH - Income Tax

Reopening and Section 153C jurisdiction depend on year-wise nexus, limitation, and valid satisfaction for seized material.

Reopening under section 147 turns on correct computation of the relevant assessment year and the applicable notice limitation, with the Delhi HC treating ... Reopening of assessment u/s 147 - time limit for notice - computation of the “relevant assessment year” - HC [2025 (3) TMI 228 - DELHI HIGH COURT] held ex facie evident that AY 2014-15 falls beyond the ten-year block period as set out u/s 153C r.w.s. 153A of the Act. Consequently, the impugned notice is rendered unsustainable - HELD THAT:- Issue notice on limitations as well as on the Special Leave Petitions. Issue to be tagged. Jurisdictional satisfaction u/s 153C - incriminating material having a bearing on the determination of the total income - nexus between seized material and specific assessment year(s) - distinction between Section 153A and Section 153C - abatement consequent to valid Section 153C satisfaction - no cascading/re en blanc reopening of block years - in HC order [2024 (4) TMI 461 - DELHI HIGH COURT] writ petitions are allowed and Section 153C notices are quashed insofar as they relate to the assessment years 2013-14 to 2020-21 listed in the chart, on the ground that the jurisdictional satisfaction required under Section 153C (year wise nexus of seized material to the determination of total income) was not recorded HELD THAT:- In view of Order passed by this Court [2024 (12) TMI 1068 - SC ORDER] Special Leave Petition is dismissed on the ground of delay as well as on merits. Outcome: Special Leave Petition dismissed as delay.