Limitation for Section 153C proceedings barred initiation for assessment year 2015-16; assessment quashed.

Initiation of proceedings under section 153C for assessment year 2015-16 was barred by limitation because the search-related satisfaction note was recorded on 25-06-2021, from which the relevant six preceding assessment years had to be counted. The record did not show invocation of the fourth proviso to section 153A(1) or satisfaction of the conditions needed to extend the normal six-year block. Assessment year 2015-16 therefore fell outside the permissible period, and the assessment for that year 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 and whether the assessment framed for that year was liable to be quashed.

Analysis: The search-related satisfaction note was recorded on 25-06-2021, and the relevant six preceding assessment years had to be computed from that date. The record did not show invocation of the fourth proviso to section 153A(1) of the Income-tax Act, 1961, nor satisfaction of the conditions required to travel beyond the normal six-year block. Accordingly, assessment year 2015-16 fell outside the permissible period for initiation of proceedings under section 153C of the Income-tax Act, 1961.

Conclusion: The initiation of proceedings for assessment year 2015-16 under section 153C of the Income-tax Act, 1961 was barred by limitation and the assessment for that year was quashed.

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