Section 153C limitation barred reassessment where the satisfaction note date placed the years outside the permissible period.

Assessments for Assessment Years 2014-15 and 2015-16 were held time barred under Section 153C because the satisfaction note was recorded on 29.09.2021, relatable to Assessment Year 2022-23. On that footing, only the immediately preceding six assessment years could ordinarily fall within the provision, and the record did not show satisfaction for the extended ten years claimed by the Revenue. Applying the cited Delhi High Court principle, the assessments for both years fell outside the permissible period and were quashed in favour of the assessee.

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Issues: Whether the assessments for Assessment Years 2014-15 and 2015-16 were barred by limitation under Section 153C of the Income-tax Act, 1961 on the basis of the date on which the satisfaction note was recorded.

Analysis: The satisfaction note under Section 153C was recorded on 29.09.2021, relatable to Assessment Year 2022-23. On that basis, only the immediately preceding six assessment years would ordinarily be within the permissible reach of the provision. The record did not show recording of satisfaction for the extended ten assessment years pleaded by the Revenue. Following the binding principle applied from the cited Delhi High Court decision, the assessments for the two years under appeal fell outside the permissible period and could not be sustained.

Conclusion: The assessments for Assessment Years 2014-15 and 2015-16 were time barred and stood quashed in favour of the assessee.

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