Section 153C limitation barred assessments when the ten-year block was counted from the satisfaction note date.

Assessments framed under section 153C for assessment years 2010-11 to 2013-14 were held time-barred because the ten-year block period had to be computed backward from the assessment year linked to the satisfaction note recorded on 07.02.2023. Seized documents from a search in another group case were handed over to the assessee's Assessing Officer, but applying the governing jurisdictional High Court ruling, the relevant block did not extend to those years. The assessments under section 143(3) read with section 153C were therefore quashed, and the revenue's challenge failed.

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Issues: Whether the assessments framed under section 153C for assessment years 2010-11 to 2013-14 were barred by limitation as they fell outside the ten-year block period computed from the date of recording of satisfaction in the assessee's case.

Analysis: A search under section 132 had taken place in another group case, and seized documents relating to the assessee were later handed over to the assessee's Assessing Officer. The satisfaction note in the assessee's case was recorded on 07.02.2023, and the assessments were completed under section 143(3) read with section 153C. Applying the jurisdictional High Court ruling governing the computation of the block period under section 153C, the relevant ten assessment years were held to run from assessment year 2024-25 backwards, which would not cover assessment years 2010-11 to 2013-14.

Conclusion: The assessments for assessment years 2010-11 to 2013-14 were rightly quashed as time-barred, and the revenue's challenge failed.

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