https://www.taxtmi.com/caselaws?id=792894 For assessment year 2021-22, the relevant six-year block for section 153C proceedings was to be counted from the deemed date of search, namely when the satisfaction note was recorded and the seized material was received by the jurisdictional Assessing Officer of the non-searched person. Applying the settled position stated to have been affirmed by the Supreme Court and the jurisdictional HC, the year fell within that block period, so the assessment ought to have been framed under section 153C and not under section 143(3). The contrary notice and assessment were treated as unsustainable, and the Revenue's challenge failed. en-us Fri, 15 May 2026 00:00:00 +0530 Fri, 05 Jun 2026 08:07:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792894 For assessment year 2021-22, the relevant six-year block for section 153C proceedings was to be counted from the deemed date of search, namely when the satisfaction note was recorded and the seized material was received by the jurisdictional Assessing Officer of the non-searched person. Applying the settled position stated to have been affirmed by the Supreme Court and the jurisdictional HC, the year fell within that block period, so the assessment ought to have been framed under section 153C and not under section 143(3). The contrary notice and assessment were treated as unsustainable, and the Revenue's challenge failed. Case-Laws Income Tax Fri, 15 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792894