https://www.taxtmi.com/caselaws?id=787726 Challenge to assessments initiated under Section 153C turns on two legal points: jurisdiction and limitation. First, recording of a satisfaction note by the assessing officer of the searched person is treated as a jurisdictional prerequisite for transmitting seized material and initiating proceedings under Section 153C; absence of that satisfaction note renders the proceedings and assessment without jurisdiction and liable to be quashed. Second, the date of satisfaction/handing over of seized material is to be treated as the search date for computing limitation; where so computed earlier assessment years fall outside the permissible block and those assessments are time barred and quashed. en-us Wed, 25 Feb 2026 00:00:00 +0530 Wed, 11 Mar 2026 08:18:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787726 Challenge to assessments initiated under Section 153C turns on two legal points: jurisdiction and limitation. First, recording of a satisfaction note by the assessing officer of the searched person is treated as a jurisdictional prerequisite for transmitting seized material and initiating proceedings under Section 153C; absence of that satisfaction note renders the proceedings and assessment without jurisdiction and liable to be quashed. Second, the date of satisfaction/handing over of seized material is to be treated as the search date for computing limitation; where so computed earlier assessment years fall outside the permissible block and those assessments are time barred and quashed. Case-Laws Income Tax Wed, 25 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787726