Section 153C block period begins on receipt of seized material, making earlier assessment years outside jurisdiction.

For section 153C proceedings, the six-year or ten-year block period for a non-searched person is computed from the date seized material is received by the jurisdictional Assessing Officer, by virtue of the first proviso's legal fiction. Applying that reference date, the relevant assessment year was 2023-24, so the ten assessment years ran only from 2014-15 onwards. Assessment years 2010-11 and 2011-12 therefore fell outside the permissible block period, and the assessment for those years was without valid jurisdiction under section 153C. The Revenue's challenge was rejected.

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Issues: Whether, for proceedings under section 153C of the Income-tax Act, 1961, the block period is to be computed from the date of receipt of seized material by the Assessing Officer of the non-searched person, and whether the assessments for assessment years 2010-11 and 2011-12 were barred as beyond the permissible block period.

Analysis: The first proviso to section 153C creates a legal fiction that, for a non-searched person, the relevant date for computing the six-year or ten-year block is the date on which books of account, documents or assets are received by the jurisdictional Assessing Officer. On that basis, the deemed date of search in the present case was the date of recording of satisfaction and handing over of material to the Assessing Officer of the assessee. Once that date is treated as the reference point, the relevant assessment year becomes 2023-24 and the ten assessment years would run only from 2014-15 onwards. The impugned assessment years 2010-11 and 2011-12 therefore lay outside the permissible block period.

Conclusion: The assessment for the impugned years was without valid jurisdiction under section 153C and the Revenue's challenge was rejected.

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