Section 153C six-year block must be counted from satisfaction date, invalidating a parallel Section 143(3) assessment.

For Section 153C assessments, the six preceding assessment years are reckoned from the date of recording satisfaction or handing over seized material, as applicable. On the admitted facts, satisfaction was recorded on 04.10.2022, bringing the assessment year in question within that six-year block. The year under appeal therefore had to be assessed under Section 153C, and the assessment completed under Section 143(3) could not validly stand. The Revenue's challenge accordingly failed, and the assessment order was held unsustainable.

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Issues: Whether the assessment for the year under appeal, completed under Section 143(3) of the Income-tax Act, 1961, was liable to be treated as one required to be made under Section 153C of the Income-tax Act, 1961, because it fell within the relevant six preceding assessment years counted from the date of recording satisfaction.

Analysis: The appeal turned on the settled principle that, for assessment of a person other than the searched person under Section 153C of the Income-tax Act, 1961, the six preceding assessment years are computed from the date of handing over of seized material or the date of recording satisfaction, as applicable. On the admitted facts, the satisfaction was recorded on 04.10.2022, and the relevant six assessment years therefore extended to cover the assessment year in question. Since the year under appeal fell within that block, the assessment made under Section 143(3) could not stand.

Conclusion: The assessment for the year under appeal was liable to be made under Section 153C and the assessment under Section 143(3) was vitiated.

Final Conclusion: The Revenue's challenge failed, and the assessment order did not survive.

Ratio Decidendi: For Section 153C assessments, the six preceding assessment years are to be reckoned from the date of recording satisfaction or handing over of seized material, and an assessment year falling within that block cannot validly be completed under Section 143(3).

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