Gujarat High Court Judgments — 2019

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the relevant assessment years contemplated under Section 153A of the Act, for the purpose of proceedings under Section 153C, are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these years is the search or requisition. For HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 4.12.2014 and 13.3.2015 respectively, the relevant previous year was 2014-15, making the assessment year 2015-16. The six preceding assessment years were 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The court did not delve into individual satisfaction notes or other issues raised, focusing solely on the jurisdictional aspect of the notices.

The High Court held that the trigger point for issuing a notice under Section 153A (and consequently Section 153C) is a search under Section 132 or requisition under Section 132A. The assessment years for which income is to be assessed or reassessed are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The Court clarified that for HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, searches on 4.12.2014 and 13.3.2015 respectively, meant the relevant previous year was 2014-15 and assessment year 2015-16, making the six preceding assessment years 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The Court did not delve into the merits of individual satisfaction notes, focusing on the jurisdictional issue.

The High Court held that the trigger point for issuing a notice under Section 153A (and consequently Section 153C) is a search under Section 132 or requisition under Section 132A. The assessment years for which income is to be assessed or reassessed are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The Court clarified that for HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, searches on 4.12.2014 and 13.3.2015 respectively, meant the relevant previous year was 2014-15 and assessment year 2015-16, making the six preceding assessment years 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The Court did not delve into the merits of individual satisfaction notes, focusing on the jurisdictional issue.

The High Court held that the trigger point for issuing a notice under Section 153A (and consequently Section 153C) is a search under Section 132 or requisition under Section 132A. The assessment years for which income is to be assessed or reassessed are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The Court clarified that for HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, searches on 4.12.2014 and 13.3.2015 respectively, meant the relevant previous year was 2014-15 and assessment year 2015-16, making the six preceding assessment years 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The Court did not delve into the merits of individual satisfaction notes, focusing on the jurisdictional issue.

The High Court held that the trigger point for issuing a notice under Section 153A (and consequently Section 153C) is a search under Section 132 or requisition under Section 132A. The assessment years for which income is to be assessed or reassessed are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The Court clarified that for HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, searches on 4.12.2014 and 13.3.2015 respectively, meant the relevant previous year was 2014-15 and assessment year 2015-16, making the six preceding assessment years 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The Court did not delve into the merits of individual satisfaction notes, focusing on the jurisdictional issue.

The High Court held that the trigger point for issuing a notice under Section 153A (and consequently Section 153C) is a search under Section 132 or requisition under Section 132A. The assessment years for which income is to be assessed or reassessed are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The Court clarified that for HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, searches on 4.12.2014 and 13.3.2015 respectively, meant the relevant previous year was 2014-15 and assessment year 2015-16, making the six preceding assessment years 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The Court did not delve into the merits of individual satisfaction notes, focusing on the jurisdictional issue.

The High Court held that the trigger point for issuing a notice under Section 153A (and consequently Section 153C) is a search under Section 132 or requisition under Section 132A. The assessment years for which income is to be assessed or reassessed are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The Court clarified that for HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, searches on 4.12.2014 and 13.3.2015 respectively, meant the relevant previous year was 2014-15 and assessment year 2015-16, making the six preceding assessment years 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The Court did not delve into the merits of individual satisfaction notes, focusing on the jurisdictional issue.

The High Court held that the trigger point for issuing a notice under Section 153A (and consequently Section 153C) is a search under Section 132 or requisition under Section 132A. The assessment years for which income is to be assessed or reassessed are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The Court clarified that for HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, searches on 4.12.2014 and 13.3.2015 respectively, meant the relevant previous year was 2014-15 and assessment year 2015-16, making the six preceding assessment years 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The Court did not delve into the merits of individual satisfaction notes, focusing on the jurisdictional issue.

The High Court held that the trigger point for issuing a notice under Section 153A (and consequently Section 153C) is a search under Section 132 or requisition under Section 132A. The assessment years for which income is to be assessed or reassessed are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The Court clarified that for HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, searches on 4.12.2014 and 13.3.2015 respectively, meant the relevant previous year was 2014-15 and assessment year 2015-16, making the six preceding assessment years 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The Court did not delve into the merits of individual satisfaction notes, focusing on the jurisdictional issue.

The High Court held that the trigger point for issuing a notice under Section 153A (and consequently Section 153C) is a search under Section 132 or requisition under Section 132A. The assessment years for which income is to be assessed or reassessed are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The Court clarified that for HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, searches on 4.12.2014 and 13.3.2015 respectively, meant the relevant previous year was 2014-15 and assessment year 2015-16, making the six preceding assessment years 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The Court did not delve into the merits of individual satisfaction notes, focusing on the jurisdictional issue.

The High Court held that the trigger point for issuing a notice under Section 153A (and consequently Section 153C) is a search under Section 132 or requisition under Section 132A. The assessment years for which income is to be assessed or reassessed are the six assessment years immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The Court clarified that for HN Safal Group, where the search was on 4.9.2013, the relevant previous year was 2013-14, making the assessment year 2014-15. Thus, the six preceding assessment years were 2013-14 to 2008-09. For Barter Group and Venus Group, searches on 4.12.2014 and 13.3.2015 respectively, meant the relevant previous year was 2014-15 and assessment year 2015-16, making the six preceding assessment years 2014-15 to 2009-10. Notices issued for assessment years beyond these six years were held to be without jurisdiction. The Court did not delve into the merits of individual satisfaction notes, focusing on the jurisdictional issue.

The High Court held that the six assessment years contemplated under Section 153A of the Income Tax Act, 1961, for proceedings under Section 153C, are those immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these six years is the search/requisition, not the issuance of the notice under Section 153C. For HN Safal Group, where the search was on 04.09.2013 (previous year 2013-14, assessment year 2014-15), the relevant six assessment years are 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 04.12.2014 and 13.03.2015 respectively (previous year 2014-15, assessment year 2015-16), the relevant six assessment years are 2014-15 to 2009-10. Notices issued for assessment years beyond these periods were held to be without jurisdiction. The Court did not delve into the merits of individual satisfaction notes, focusing solely on the jurisdictional aspect of Section 153C.

The High Court held that the six assessment years contemplated under Section 153A of the Income Tax Act, 1961, for proceedings under Section 153C, are those immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these six years is the search/requisition, not the issuance of the notice under Section 153C. For HN Safal Group, where the search was on 04.09.2013 (previous year 2013-14, assessment year 2014-15), the relevant six assessment years are 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 04.12.2014 and 13.03.2015 respectively (previous year 2014-15, assessment year 2015-16), the relevant six assessment years are 2014-15 to 2009-10. Notices issued for assessment years beyond these periods were held to be without jurisdiction. The Court did not delve into the merits of individual satisfaction notes, focusing solely on the jurisdictional aspect of Section 153C.

The High Court held that the six assessment years contemplated under Section 153A of the Income Tax Act, 1961, for proceedings under Section 153C, are those immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these six years is the search/requisition, not the issuance of the notice under Section 153C. For HN Safal Group, where the search was on 04.09.2013 (previous year 2013-14, assessment year 2014-15), the relevant six assessment years are 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 04.12.2014 and 13.03.2015 respectively (previous year 2014-15, assessment year 2015-16), the relevant six assessment years are 2014-15 to 2009-10. Notices issued for assessment years beyond these periods were held to be without jurisdiction. The Court did not delve into the merits of individual satisfaction notes, focusing solely on the jurisdictional aspect of Section 153C.

The High Court held that the six assessment years contemplated under Section 153A of the Income Tax Act, 1961, for proceedings under Section 153C, are those immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these six years is the search/requisition, not the issuance of the notice under Section 153C. For HN Safal Group, where the search was on 04.09.2013 (previous year 2013-14, assessment year 2014-15), the relevant six assessment years are 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 04.12.2014 and 13.03.2015 respectively (previous year 2014-15, assessment year 2015-16), the relevant six assessment years are 2014-15 to 2009-10. Notices issued for assessment years beyond these periods were held to be without jurisdiction. The Court did not delve into the merits of individual satisfaction notes, focusing solely on the jurisdictional aspect of Section 153C.

The High Court held that the six assessment years contemplated under Section 153A of the Income Tax Act, 1961, for proceedings under Section 153C, are those immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these six years is the search/requisition, not the issuance of the notice under Section 153C. For HN Safal Group, where the search was on 04.09.2013 (previous year 2013-14, assessment year 2014-15), the relevant six assessment years are 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 04.12.2014 and 13.03.2015 respectively (previous year 2014-15, assessment year 2015-16), the relevant six assessment years are 2014-15 to 2009-10. Notices issued for assessment years beyond these periods were held to be without jurisdiction. The Court did not delve into the merits of individual satisfaction notes, focusing solely on the jurisdictional aspect of Section 153C.

The High Court held that the six assessment years contemplated under Section 153A of the Income Tax Act, 1961, for proceedings under Section 153C, are those immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these six years is the search/requisition, not the issuance of the notice under Section 153C. For HN Safal Group, where the search was on 04.09.2013 (previous year 2013-14, assessment year 2014-15), the relevant six assessment years are 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 04.12.2014 and 13.03.2015 respectively (previous year 2014-15, assessment year 2015-16), the relevant six assessment years are 2014-15 to 2009-10. Notices issued for assessment years beyond these periods were held to be without jurisdiction. The Court did not delve into the merits of individual satisfaction notes, focusing solely on the jurisdictional aspect of Section 153C.

The High Court held that the six assessment years contemplated under Section 153A of the Income Tax Act, 1961, for proceedings under Section 153C, are those immediately preceding the assessment year relevant to the previous year in which the search or requisition was conducted. The trigger point for determining these six years is the search/requisition, not the issuance of the notice under Section 153C. For HN Safal Group, where the search was on 04.09.2013 (previous year 2013-14, assessment year 2014-15), the relevant six assessment years are 2013-14 to 2008-09. For Barter Group and Venus Group, with searches on 04.12.2014 and 13.03.2015 respectively (previous year 2014-15, assessment year 2015-16), the relevant six assessment years are 2014-15 to 2009-10. Notices issued for assessment years beyond these periods were held to be without jurisdiction. The Court did not delve into the merits of individual satisfaction notes, focusing solely on the jurisdictional aspect of Section 153C.