Section 153C block period for non-searched persons runs from receipt of seized material, making regular assessment invalid.

For a non-searched person, the six assessment years under Section 153C of the Income-tax Act, 1961 are reckoned from the date the jurisdictional Assessing Officer receives the seized books, documents, or assets, not from the date of search on the searched person. On that basis, an assessment year falling within that block must be taken up under Section 153C and not under the regular assessment route under Section 143(3). If the assessment is completed without following the mandatory Section 153C procedure, it suffers from a jurisdictional defect and is liable to be quashed.

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Issues: Whether the assessment for the relevant year, in the case of a non-searched person, was required to be completed under Section 153C of the Income-tax Act, 1961 on the basis of the date of receipt of seized material or satisfaction note, and whether the assessment framed under Section 143(3) of the Income-tax Act, 1961 was invalid.

Analysis: The block period for a non-searched person under Section 153C is to be computed from the date on which the jurisdictional Assessing Officer receives the seized books, documents, or assets, and not from the date of search on the searched person. Applying this settled position, the year under consideration fell within the six-year block linked to the date of satisfaction and receipt of seized material. The assessment was therefore required to be initiated under Section 153C, and not under the regular assessment route under Section 143(3) of the Income-tax Act, 1961. Since the assessment was framed without following the mandatory Section 153C procedure, it suffered from a jurisdictional defect.

Conclusion: The assessment framed under Section 143(3) was rightly held to be bad in law, and the notice and consequential assessment order were liable to be quashed.

Ratio Decidendi: For a non-searched person, the six assessment years under Section 153C of the Income-tax Act, 1961 are reckoned from the date the seized material is received by the jurisdictional Assessing Officer, and an assessment year falling within that block must be assessed under Section 153C rather than under Section 143(3).

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