Limitation under section 153C turns on the date of search, not later handover of seized material, making the assessment time-barred.

Proceedings under section 153C were treated as time-barred because the six-year and ten-year block period had to be computed from the date of search, not from the later date when seized material was handed over to the jurisdictional Assessing Officer or satisfaction was recorded. The Tribunal read sections 153A and 153C together, relied on the Finance Act, 2017 scheme and the CBDT circular, and followed the binding judicial position that the block period cannot be shifted to the date of transfer of documents. On that basis, the limitation ground succeeded and the Revenue's challenge failed.

---

---

Issues: Whether the assessment framed under section 153C for the relevant assessment year was barred by limitation, and whether the block period had to be reckoned from the date of search or from the date on which seized materials were handed over to the jurisdictional Assessing Officer of the non-searched person.

Analysis: The Tribunal examined the scheme of sections 153A and 153C together and held that the computation of the six-year and ten-year block for proceedings under section 153C was to be aligned with the date of search, not the later date of transfer of seized documents or recording of satisfaction. It noted the legislative intent reflected in the Finance Act, 2017 amendments and the CBDT circular, and followed the binding judicial position that the relevant block period, in the context of the case, could not be shifted to the date of handover of documents to the jurisdictional Assessing Officer.

Conclusion: The assessment under section 153C was held to be time-barred, and the Revenue's challenge to the order allowing the assessee's limitation ground failed.

---