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“block period”

Chapter XIV-B - Block AssessmentSection 158B - Block PeriodSection 158B(a)1,340 judgments

The decision most relied on for block period is CIT v. Calcutta Knitwears (362 ITR 673), cited in 528 judgments on BharatTax.

Leading authorities on block period

CIT v. Calcutta Knitwears
362 ITR 673 · 2014 · Supreme Court
528
citing judgments

The recording of a satisfaction note by the Assessing Officer is a jurisdictional prerequisite for assessments under Section 153C, and the six-year limitation period for such assessments is reckoned from the date this satisfaction is recorded.

PCIT v. Ojjus Medicare (P) Ltd.
465 ITR 101 · 2024 · High Court
277
citing judgments

For assessments under Section 153C, the commencement point for calculating the six or ten assessment year block period is the date of issuing the Section 153C notice, or the date of the satisfaction note/handing over of books, as clarified by the first proviso to Section 153C(1).

Jai Steel (India) v. Asstt. CIT
36 Taxmann.com 523 · 2013 · High Court
267
citing judgments

An assessee cannot claim deductions or expenditures in a Section 153A assessment that were not claimed in the original completed assessment, even if documents were found during a search.

CIT v. Jasjit Singh
155 Taxmann.com 155 · 2023 · Supreme Court
235
citing judgments

For assessments under Section 153C concerning a non-searched person, the relevant date for calculating the block of assessment years is the date on which the jurisdictional Assessing Officer of that person assumes possession of the seized material, not the date of the original search. This date determines the look-back period for reopening assessments under Section 153A read with 153C.

Indian National Congress v. DCIT
463 ITR 431 · 2024 · High Court
167
citing judgments

A consolidated satisfaction note covering multiple assessment years is valid for initiating proceedings under section 153C, provided the seized material and the additions rest on incriminating evidence pertaining to those years.

Pr. CIT v. Sarwar Agency P. Ltd.
397 ITR 400 · 2017 · High Court
95
citing judgments

An assessment initiated under Section 153C against a person other than the searched person is invalid if the Assessing Officer of the searched person fails to record a proper satisfaction note as mandated by the section. The procedural requirement of a satisfaction note is crucial for the validity of such an assessment.

CIT, Panji v. Dempo Company Limited
74 Taxmann.com 15 · 2016 · Supreme Court
62
citing judgments

The 20% tax rate under Section 112 applies to capital gains arising from the transfer of a depreciable asset, even if it is deemed a short-term capital gain under Section 50, provided the asset was held for more than 36 months. The fiction created by Section 50 for treating such gains as short-term does not alter the long-term nature of the asset for applying the tax rate under Section 112.

CIT v. Anil Kumar Bhatia (supra) and CIT v. Chetan Das Lachman Das
254 CTR 392 · 2012 · High Court
57
citing judgments

Additions cannot be made to assessments under Sections 153A and 153C if no incriminating material was found during a search operation. Assessments for each year preceding the search are distinct and separate.

Judgments citing block period

Quadra Infratel Synergies Pvt Ltd, Delhi vs. ACIT, Central Circle 4, Delhi, Jhandewalan

In the result, the appeal of the assessee is allowed as indicated above

ITA 3963/DEL/2024[2014-15]Status: DisposedITAT Delhi12 Dec 2025AY 2014-15

Bench: Shri C.N. Prasad & Shri M. Balaganesh[Assessment Year: 2014-15] Quadra Infratel Synergies Vs. Acit Pvt. Ltd. B-6/1, Sector-05 Central Circle – 4 Rohini, Delhi Delhi Pan No. Aaecp2894G Appellant Respondent Assessee By Sh. Saksham Singhal, Advocate Ms. Somay Jain, Ca Revenue By Ms. Nimisha Singh, Cit Dr Date Of Hearing 18.09.2025 Date Of Pronouncement 12.12.2025 Order Per C.N. Prasad, Jm, This Appeal Filed By The Assessee Is Preferred Against The Order Of The Commissioner Of Income Tax (Appeals), Delhi - 110023 [Herein After Referred As “Cit(A)”] Dated 29.06.2024 For A.Y. 2014-15. 2. The Assessee Has Raised Following Grounds On Validity Of Assessment Proceedings :- “1. That On The Facts & Circumstances Of The Case & In Law, The Commissioner Of Income Tax (Appeals) ['Cit(A)'] Erred In Not Completely Allowing The Appeal Filed By The Appellant Against The Order Dated 29.03.2023 Passed By The Assessing Officer Under Section 1530 R.W.S 143(3) Of The Income Tax Act, 1961 ('The Act").

Section 143(3)Section 153Section 153ASection 153CSection 153DSection 28Section 69A

Assessee is on 26.10.2021. Thereafter, the AO of the assessee recorded satisfaction note on 24.01.2022. The Ld. Counsel for the assessee submitted that the block period for making assessment u/s.153C was considered by the AO taking the year of search in the case of A-Tek Enterprises Ltd. as first ... searched person shall be considered as year of search for the purpose of section 153C and in which case block period of six assessment years shall be from 2022-23 to 2016-17, since the date of handing over of documents by the AO of the searched person