2025 (5) TMI 1801

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....r the Respondent Through: Mr. Abhishek Maratha, SSC, Mr. Apoorv Aggarwal, Mr. Parth Samwal, JSCs alongwith Ms. Nupur Sharma, Mr. Gaurav Singh, Mr. Bhanukaran Singh Jodha, Ms. Muskan Goel & Mr. Himanshu Gaur, Advocates. VIBHU BAKHRU, J. (ORAL) 1. The petitioner has filed the present petition impugning a notice dated 29.07.2022 [impugned notice] issued under Section 153C of the Income Tax Act, 196....

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....It is alleged that during the course of search, certain incriminating material was found, which belonged to the petitioner or contained information relating to the petitioner. Accordingly, the Assessing Officer having jurisdiction over the said searched entity penned down a satisfaction note dated 01.06.2022 to the effect that the material found either belonged to the petitioner or contained infor....

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....07.2022. The said statement is set out below: Year of Satisfaction Assessment Years 1 AY 2022-23 2 AY 2021-22 3 AY 2020-21 4 AY 2019-20 5 AY 2018-19 6 AY 2017-18 6. Concededly, the extended period of ten years is not applicable in the present case. Thus, the assumption of jurisdiction in respect of AY 2016-17, which falls beyond the block period of six years, is not sustainable. The....