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    <title>2026 (5) TMI 1768 - ITAT DELHI</title>
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    <description>Assessments initiated under section 153C were held to be beyond the permissible ten-year block period because the satisfaction note was recorded much later than the statutory trigger date used for computing the extended search assessment period. Applying the prevailing interpretation of the section 153A block period, as extended to section 153C proceedings, the assessments for the relevant years were treated as lacking jurisdiction and therefore bad in law. Once that preliminary defect was accepted, the remaining grounds did not survive. The appellate order dismissing the Revenue&#039;s challenge was left undisturbed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=792565</link>
      <description>Assessments initiated under section 153C were held to be beyond the permissible ten-year block period because the satisfaction note was recorded much later than the statutory trigger date used for computing the extended search assessment period. Applying the prevailing interpretation of the section 153A block period, as extended to section 153C proceedings, the assessments for the relevant years were treated as lacking jurisdiction and therefore bad in law. Once that preliminary defect was accepted, the remaining grounds did not survive. The appellate order dismissing the Revenue&#039;s challenge was left undisturbed.</description>
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