Section 153C limitation runs from satisfaction note date, making out-of-block assessments without valid jurisdiction.

For proceedings under section 153C, the six assessment years are to be reckoned from the date of recording of satisfaction by the Assessing Officer of the searched person or the assessee, in line with the statutory scheme including Explanation 1 to section 153A. Applying that computation, assessment years 2014-15 and 2015-16 fell outside the permissible six-year block and the assessments were therefore without valid jurisdiction. Once the jurisdictional objection succeeded, the remaining grounds did not require adjudication and were left open as academic.

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Issues: Whether the assessments framed under section 153C for the assessment years 2014-15 and 2015-16 were valid when the years fell outside the six-year block period computed from the date of recording of satisfaction.

Analysis: The search was conducted on 18.10.2019 and the satisfaction note for initiating proceedings under section 153C was recorded on 04.11.2022. The applicable legal position is that the six assessment years for section 153C are to be reckoned with reference to the date of recording of satisfaction by the Assessing Officer of the searched person or the assessee, and the computation is governed by the statutory scheme, including Explanation 1 to section 153A. Applying that principle, the assessment years 2014-15 and 2015-16 fell outside the permissible six-year period. As the jurisdictional challenge succeeded, the remaining grounds did not require adjudication.

Conclusion: The assessments for assessment years 2014-15 and 2015-16 were held to be bad in law as being beyond the six-year period, and the objection to jurisdiction was allowed in favour of the assessee.

Final Conclusion: The impugned assessments did not survive the limitation challenge, and the other issues were left open as academic.

Ratio Decidendi: For proceedings under section 153C, the six-year period is to be computed with reference to the date of recording of satisfaction, and any assessment made beyond that period is without valid jurisdiction.

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