https://www.taxtmi.com/caselaws?id=773930 Section 153C proceedings must be founded on a recorded satisfaction note based on seized material that objectively links the other person to incriminating income; a mechanical note without such nexus fails the jurisdictional test, so the assessments for AYs 2009-10 to 2012-13 were quashed. Limitation for section 153C is computed from the date satisfaction is recorded, and where that date falls beyond the permissible six-year block, the assessment is time-barred; on that basis, AY 2008-09 was beyond limitation and could not be sustained. en-us Fri, 27 Jun 2025 00:00:00 +0530 Mon, 30 Jun 2025 08:46:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773930 Section 153C proceedings must be founded on a recorded satisfaction note based on seized material that objectively links the other person to incriminating income; a mechanical note without such nexus fails the jurisdictional test, so the assessments for AYs 2009-10 to 2012-13 were quashed. Limitation for section 153C is computed from the date satisfaction is recorded, and where that date falls beyond the permissible six-year block, the assessment is time-barred; on that basis, AY 2008-09 was beyond limitation and could not be sustained. Case-Laws Income Tax Fri, 27 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773930