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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

Hemant Naresh Agarwal, Surat vs. Assistant Commissioner of Income Tax, Central Cir. 4, Surat

In the result, appeal of assessee is dismissed

ITA 170/SRT/2023[2020-21]Status: DisposedITAT Surat24 Oct 2025AY 2020-21

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआ.(खो और ज).सं /It(Ss)A No.68 & 70/Srt/2023 Assessment Years: 2015-16 & 2018-19 (Physical Court Hearing) Deputy Commissioner Of Hemant Naresh Agarwal बनाम/ Income-Tax, Central Circle-4, 701, Shree Shyam Awas, Bhatar Vs. Surat Room No.508, 5Th Floor, Road, Near Vidhya Bharti School, Aayakar Bhawan, Majura Surat-395 010 Gate, Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Auppa 9003 J (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita.No.170/Srt/2023 Assessment Year: 2020-21 Hemant Naresh Agarwal Assistant Commissioner Of बनाम/ 701, Shree Shyam Awas, Bhatar Income-Tax, Central Circle-4, Vs. Road, Near Vidhya Bharti School, Surat, Aaykar Bhawan, Surat-395 010 Majura Gate, Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Auppa 9003 J (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Assessee By Shri Kiran K. Shah राज" की ओर से /Revenue By Shri Mukesh Jain, Cit-Dr & Shri Kevin Langaliya, Ca सुनवाई की तारीख/Date Of Hearing 18/09/2025 उद्घोषणा की तारीख/Date Of Pronouncement 24/10/2025

Section 143(3)Section 250Section 292CSection 69

absolutely no corroborative evidence for actual investment as estimated. The Respondent also urges that, there are several properties which were acquired prior to block period and for that also, huge estimate is made against such properties. The Respondent therefore, urges that such paper ought to be considered as dumb paper