Section 153C limitation in search cases depends on the relevant search date; proceedings outside the six-year block fail.

For Section 153C proceedings, the relevant search date qua the assessee governs computation of the six-year block, and proceedings beyond that period cannot be sustained unless the statutory conditions for extension are specifically met. The satisfaction note was recorded on 25-06-2021, so the permissible block began only from assessment year 2016-17. Assessment year 2015-16 therefore fell outside the statutory block, and no valid basis for extended jurisdiction was shown in the note. The proceedings for assessment year 2015-16 were held barred by limitation and the assessment was quashed.

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Issues: Whether initiation of proceedings under Section 153C of the Income-tax Act, 1961 for assessment year 2015-16 was barred by limitation as being beyond the block period of six preceding assessment years.

Analysis: The search-related satisfaction note was recorded on 25-06-2021, which was treated as the relevant search date qua the assessee for Section 153C proceedings. Counting six preceding assessment years from that date, the permissible block commenced only from assessment year 2016-17. The assessee's assessment year 2015-16 therefore fell outside the statutory block. The conditions for extending jurisdiction beyond six years under the fourth proviso to Section 153A(1) of the Income-tax Act, 1961 were not shown to have been satisfied in the satisfaction note, and no valid basis existed to initiate proceedings for assessment year 2015-16.

Conclusion: Initiation of proceedings for assessment year 2015-16 under Section 153C of the Income-tax Act, 1961 was barred by limitation and the assessment was quashed, in favour of the assessee.

Ratio Decidendi: For Section 153C proceedings, the relevant search date qua the assessee governs computation of the six-year block, and proceedings beyond that block cannot be sustained unless the statutory conditions for extension are specifically satisfied.

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