https://www.taxtmi.com/caselaws?id=799283 Assessment of a non-searched person under Section 153C requires compliance with the six-year limitation period, calculated with reference to receipt of material or recording of jurisdictional satisfaction. Proceedings are time-barred where the relevant assessment year falls outside that period. A recorded satisfaction note is a jurisdictional requirement; mere reference to receipt and perusal of information does not establish valid assumption of jurisdiction. Approval under Section 153D must demonstrate meaningful consideration of draft assessment orders and cannot be mechanical. Failure of limitation, satisfaction, or reasoned approval requirements renders Section 153C proceedings void ab initio. en-us Wed, 08 Jul 2026 00:00:00 +0530 Sat, 19 Sep 2026 08:20:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799283 Assessment of a non-searched person under Section 153C requires compliance with the six-year limitation period, calculated with reference to receipt of material or recording of jurisdictional satisfaction. Proceedings are time-barred where the relevant assessment year falls outside that period. A recorded satisfaction note is a jurisdictional requirement; mere reference to receipt and perusal of information does not establish valid assumption of jurisdiction. Approval under Section 153D must demonstrate meaningful consideration of draft assessment orders and cannot be mechanical. Failure of limitation, satisfaction, or reasoned approval requirements renders Section 153C proceedings void ab initio. Case-Laws Income Tax Wed, 08 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799283