Jurisdictional time limit for search assessments under section 153C led to quashing of assessments beyond the permissible block period.

Assessments initiated under section 153C were held to be beyond the permissible ten-year block period because the satisfaction note was recorded much later than the statutory trigger date used for computing the extended search assessment period. Applying the prevailing interpretation of the section 153A block period, as extended to section 153C proceedings, the assessments for the relevant years were treated as lacking jurisdiction and therefore bad in law. Once that preliminary defect was accepted, the remaining grounds did not survive. The appellate order dismissing the Revenue's challenge was left undisturbed.

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Issues: Whether the assessments framed under section 153C of the Income-tax Act, 1961 for the relevant assessment years were without jurisdiction as they fell outside the permissible ten-year block period and were liable to be quashed.

Analysis: The search was conducted under section 132 of the Income-tax Act, 1961 and the satisfaction note for initiating proceedings under section 153C was recorded much later. The governing interpretation of the extended search assessment period under section 153A, as applied to section 153C proceedings, required computation of the block period with reference to the relevant statutory trigger date. Following the binding jurisdictional and other High Court decisions relied upon by the lower appellate authority, the impugned assessments for the assessment years in question were found to have been initiated beyond the permissible ten-year period. Once the assessments were held invalid on this preliminary jurisdictional ground, the remaining grounds did not survive for adjudication.

Conclusion: The assessments under section 153C for the relevant assessment years were rightly held to be bad in law and were quashed, leaving no infirmity in the appellate order dismissing the Revenue's challenge.

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