Section 153C jurisdiction fails where the assessment year falls outside the six-year block counted from satisfaction note date.

For proceedings under section 153C, the six assessment years are computed with reference to the date of recording of satisfaction in the assessee's case, treated as the date of search qua that assessee. Applying that principle, the satisfaction note dated 24.06.2022 fixed the relevant block period, and assessment year 2016-17 fell outside it. The assumption of jurisdiction for that year was therefore invalid, and the assessment was held bad in law. The view was consistent with the jurisdictional High Court and other High Court decisions relied upon by the first appellate authority.

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Issues: Whether the assessment for assessment year 2016-17 under section 153C was valid when the year fell outside the six-year block period computed from the date of recording of satisfaction.

Analysis: The search was conducted on 30.03.2021 and the satisfaction note for initiating proceedings in the assessee's case was recorded on 24.06.2022. The governing principle applied was that, for proceedings under section 153C, the relevant six assessment years are to be computed with reference to the date of recording of satisfaction in the assessee's case, treated as the date of search qua that assessee. On that basis, assessment year 2016-17 fell outside the permissible block period. The conclusion also followed the consistent view of the jurisdictional High Court and other High Courts relied upon by the first appellate authority.

Conclusion: The assumption of jurisdiction under section 153C for assessment year 2016-17 was invalid and the assessment was rightly held to be bad in law.

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