Limitation for Section 153C notices is measured from the assessment year in which satisfaction is recorded, excluding stale assessment years.

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....Limitation for notices under Sections 153A and 153C is reckoned backward from the assessment year in which the satisfaction note is recorded. Where the note was recorded in AY 2024-25, the stated extended limitation reached only AY 2015-16. A notice for AY 2010-11 therefore fell outside the permissible period and was quashed as time-barred.....