Search-based assessment lacked jurisdiction where amended law made section 153C inapplicable to later searches.

Assessment proceedings initiated under section 153C were held to be without jurisdiction because the search and the corresponding satisfaction note related to a search initiated on 3 February 2021, while the amended legal position from 1 April 2021 rendered section 153C inapplicable to searches initiated on or after that date. The initiation of proceedings was therefore invalid, and the consequent assessment could not be sustained. The jurisdictional objection went to the root of the matter and the assessment order was quashed.

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Issues: Whether the assessment initiated under section 153C on the basis of a search conducted on or after 1 April 2021 was without authority and liable to be quashed.

Analysis: The notice under section 153C was issued after the search and recording of satisfaction in relation to a search initiated on 3 February 2021. The amended legal position applicable from 1 April 2021 rendered section 153C inapplicable to searches initiated on or after that date. On that basis, the initiation of proceedings under section 153C lacked jurisdiction, and the consequent assessment could not be sustained. The ground going to the root of jurisdiction was therefore admitted and decided on merits.

Conclusion: The impugned proceedings under section 153C were invalid and the assessment order was quashed in favour of the assessee.

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