Section 153C jurisdiction for non-searched persons turns on the handover date of seized material, making section 143(3) assessment invalid.

For a non-searched person, the date on which seized material is handed over to the jurisdictional Assessing Officer is the reference point for section 153C, and the six assessment years must be counted from that deemed date of search. On that basis, assessment year 2017-18 fell within the permissible block and had to be assessed under section 153C. An assessment framed instead under section 143(3) was not sustainable because the statutory route for a non-searched person was not followed, rendering the jurisdiction assumed under section 143(3) invalid.

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Issues: Whether, in the case of a non-searched person, the assessment year 2017-18 had to be assessed under section 153C of the Income-tax Act, 1961 on the basis of the date on which seized material was handed over to the jurisdictional Assessing Officer, and whether an assessment framed under section 143(3) was invalid.

Analysis: The seized material relating to the assessee was handed over to the jurisdictional Assessing Officer on 26.03.2019. The first proviso to section 153C treats that date as the reference point for the non-searched person, and the six assessment years are to be reckoned with reference to that deemed date of search. On that basis, the assessment years falling within the permissible block included AY 2017-18. The assessment, however, was framed under section 143(3) instead of under section 153C. Since the statutory route for assessment of a non-searched person was not followed, the assumption of jurisdiction under section 143(3) was not sustainable.

Conclusion: The assessment for AY 2017-18 was required to be made under section 153C, and the assessment framed under section 143(3) was invalid.

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