Search date determined by AO's satisfaction fixes assessment years; notices must be issued under the search provision, not 143(2).

Search date determined by AO's satisfaction fixes assessment years; notices must be issued under the search provision, not 143(2). https://www.taxtmi.com/highlights?id=96722 The date when the assessing officer records satisfaction upon receiving seized or re sequestered books or documents determines the 'date of search' for triggering search related assessments under the first proviso to section 153C; consequently the search year and the six preceding assessment years are fixed from that satisfaction date, not from the physical search date. Applying that principle to a satisfaction recorded on 24.05.2022 yields AY 2023 24 and preceding AYs 2017 18 to 2022 23; therefore assessments for AY 2021 22 should have proceeded by notice under the search provision rather than under section 143(2). en-us Mon, 09 Feb 2026 10:01:31 +0530 Mon, 09 Feb 2026 10:01:31 +0530 TaxTMI RSS Generator Search date determined by AO's satisfaction fixes assessment years; notices must be issued under the search provision, not 143(2). https://www.taxtmi.com/highlights?id=96722 The date when the assessing officer records satisfaction upon receiving seized or re sequestered books or documents determines the 'date of search' for triggering search related assessments under the first proviso to section 153C; consequently the search year and the six preceding assessment years are fixed from that satisfaction date, not from the physical search date. Applying that principle to a satisfaction recorded on 24.05.2022 yields AY 2023 24 and preceding AYs 2017 18 to 2022 23; therefore assessments for AY 2021 22 should have proceeded by notice under the search provision rather than under section 143(2). Highlights Income Tax Mon, 09 Feb 2026 10:01:31 +0530 https://www.taxtmi.com/highlights?id=96722