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ITAT held that for a non-searched person under s.153C, the "deemed date of search" is the date on which the AO records satisfaction, not the original date of search on the searched party, following the ratio of SC in Jasjit Singh. In this case, the satisfaction note was recorded on 17.02.2022, making AY 2023-24 the relevant assessment year for reckoning the six/ten-year block. Consequently, AYs 2011-12 and 2012-13 fell outside the permissible block period. ITAT upheld the CIT(A)'s decision, holding that the AO lacked valid jurisdiction and quashing the assessments for AYs 2011-12 and 2012-13 as time-barred and invalid.
ITAT held that for a non-searched person under s.153C, the "deemed date of search" is the date on which the AO records satisfaction, not the original date of search on the searched party, following the ratio of SC in Jasjit Singh. In this case, the satisfaction note was recorded on 17.02.2022, making AY 2023-24 the relevant assessment year for reckoning the six/ten-year block. Consequently, AYs 2011-12 and 2012-13 fell outside the permissible block period. ITAT upheld the CIT(A)'s decision, holding that the AO lacked valid jurisdiction and quashing the assessments for AYs 2011-12 and 2012-13 as time-barred and invalid.
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