https://www.taxtmi.com/caselaws?id=406791 Proceedings under section 153C require prior recorded satisfaction in the file of the searched person that seized material belongs to another person; without that jurisdictional step, the assessment cannot be sustained. The six-year block under the proviso is computed from the date the books, documents or assets are received by the Assessing Officer of the other person, not from the search date. On the stated facts, no such satisfaction was recorded and the assessments were framed on an incorrect block basis, so the jurisdictional foundation failed and the issue was decided in favour of the assessee. en-us Tue, 20 Apr 2021 00:00:00 +0530 Tue, 20 Apr 2021 16:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=406791 Proceedings under section 153C require prior recorded satisfaction in the file of the searched person that seized material belongs to another person; without that jurisdictional step, the assessment cannot be sustained. The six-year block under the proviso is computed from the date the books, documents or assets are received by the Assessing Officer of the other person, not from the search date. On the stated facts, no such satisfaction was recorded and the assessments were framed on an incorrect block basis, so the jurisdictional foundation failed and the issue was decided in favour of the assessee. Case-Laws Income Tax Tue, 20 Apr 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=406791