Section 153C jurisdiction depends on satisfaction-note date; post-01.04.2021 notices may fail and require section 148 route.

For search-related proceedings against a non-searched person, the legally relevant date for section 153C jurisdiction and block-period computation is the satisfaction-note date. On that basis, where an assessment year falls outside the ten-year span, section 153C proceedings are without jurisdiction and liable to be quashed. The text also states that where satisfaction is recorded after 01.04.2021, section 153C cannot be invoked in the manner adopted and the matter must proceed, if at all, under section 148; any 153C notice in that situation is unsustainable and connected additions become academic.

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Issues: (i) Whether the proceedings under section 153C of the Income-tax Act, 1961 were barred for assessment year 2014-15 as falling outside the ten-year block period; (ii) Whether the proceedings under section 153C were invalid for the later assessment years because the satisfaction was recorded after 01.04.2021 and, therefore, the case ought to have been taken under section 148.

Issue (i): Whether the proceedings under section 153C of the Income-tax Act, 1961 were barred for assessment year 2014-15 as falling outside the ten-year block period.

Analysis: The relevant date for computing the block period was taken as the date of the satisfaction note, and on that basis the assessment year in question fell outside the permissible ten-year span reckoned backwards from the relevant assessment year. The Court applied the binding interpretation that the block period under sections 153C and 153A must be computed with reference to the legally relevant assessment year linked to the satisfaction note.

Conclusion: The proceedings under section 153C for assessment year 2014-15 were held to be without jurisdiction and were quashed.

Issue (ii): Whether the proceedings under section 153C were invalid for the later assessment years because the satisfaction was recorded after 01.04.2021 and, therefore, the case ought to have been taken under section 148.

Analysis: The Court followed the view that, for satisfaction recorded after 01.04.2021, section 153C could not be invoked in the manner adopted by the revenue and that the proceedings had to be initiated under section 148. Since the notice under section 153C itself was held to be unsustainable, the connected additions and other grounds were rendered academic.

Conclusion: The proceedings under section 153C for the later assessment years were held to be invalid and were quashed.

Final Conclusion: All the appeals succeeded because the assumption of jurisdiction under section 153C was found unsustainable, and the connected matters did not survive for separate adjudication.

Ratio Decidendi: For search-related proceedings against a non-searched person, the legally relevant date for section 153C jurisdiction and block-period computation is the satisfaction-note date, and where the statutory regime makes section 153C inapplicable after 01.04.2021, the revenue cannot sustain proceedings under that provision.

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