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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

Thanushkodi Narayanan, Chennai vs. DCIT, Central Circle-3(2), Chennai

In the result, the appeals filed by the assessees in ITA Nos

ITA 2574/CHNY/2025[2014-15]Status: DisposedITAT Chennai09 Mar 2026AY 2014-15

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. G. Tarun, AdvocateFor Respondent: Ms. R. Anitha, Addl. CIT
Section 132Section 142Section 142(1)Section 143(2)Section 153A

pursuant to the search or requisition. However, instead of the earlier regime of block assessment whereby it was only the undisclosed income of the block period that was assessed, section 153A of the Act seeks to assess the total income for the assessment year, which is clear from the first ... employee in-charge of the bar. He then proceeded to finalise the block assessment under Section 158BB of the I.T. Act for the block period of five years from 1996-97 to 2000-01. The Appellate Tribunal, in an appeal preferred by the assessee, found that the statements recorded from

Thanushkodi Narayanan, Chennai vs. DCIT, Central Circle-3(2), Chennai

In the result, the appeals filed by the assessees in ITA Nos

ITA 2573/CHNY/2025[2013-14]Status: DisposedITAT Chennai09 Mar 2026AY 2013-14

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. G. Tarun, AdvocateFor Respondent: Ms. R. Anitha, Addl. CIT
Section 132Section 142Section 142(1)Section 143(2)Section 153A

pursuant to the search or requisition. However, instead of the earlier regime of block assessment whereby it was only the undisclosed income of the block period that was assessed, section 153A of the Act seeks to assess the total income for the assessment year, which is clear from the first ... employee in-charge of the bar. He then proceeded to finalise the block assessment under Section 158BB of the I.T. Act for the block period of five years from 1996-97 to 2000-01. The Appellate Tribunal, in an appeal preferred by the assessee, found that the statements recorded from

Thanushkodi Narayanan, Chennai vs. DCIT, Central Circle-3(2), Chennai

In the result, the appeals filed by the assessees in ITA Nos

ITA 2571/CHNY/2025[2012-13]Status: DisposedITAT Chennai09 Mar 2026AY 2012-13

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. G. Tarun, AdvocateFor Respondent: Ms. R. Anitha, Addl. CIT
Section 132Section 142Section 142(1)Section 143(2)Section 153A

pursuant to the search or requisition. However, instead of the earlier regime of block assessment whereby it was only the undisclosed income of the block period that was assessed, section 153A of the Act seeks to assess the total income for the assessment year, which is clear from the first ... employee in-charge of the bar. He then proceeded to finalise the block assessment under Section 158BB of the I.T. Act for the block period of five years from 1996-97 to 2000-01. The Appellate Tribunal, in an appeal preferred by the assessee, found that the statements recorded from

Thanushkodi Narayanan, Chennai vs. DCIT, Central Circle-3(2), Chennai

ITA 2570/CHNY/2025[2011-12]Status: DisposedITAT Chennai09 Mar 2026AY 2011-12

Bench: This Tribunal. 2. Since, The Facts Are The Identical Across All The Appeals / For All The Assessment Years, Except For The Nature Of The Additions / Disallowances Varying In Few Of The Assessment Year(S) Before This Tribunal In The Present Batch Of 6 Appeals, The Appeal Arising From The A.Y. 2012-13 Is Being Taken Up As The Lead Case With The Consent Of The Both The Ld. Ar As Well As The Departmental Representatives. 3. The Brief Fact Of The Present Case Is That The Assessee, Shri Thanushkodi Narayanan, Is The Managing Director Of M/S.Annai Builders Real Estates Pvt Ltd. The Assessee Filed His Original Return Of Income For The A.Y. 2012-13 On 27.09.2012 In Declaring A Total Income Of Rs.24,87,430/-. 4. A Search & Seizure Operation Was Carried Out In Terms Of Section 132 Of The Act On 04.10.2017 In The Residential Premises Of The Assessee & Also In The Premises Of M/S.Annai Builders Real Estates Pvt. Ltd. In Which The Assessee Is The Managing Director. 5. Thereafter, A Notice U/S.153A Of The Act For The A.Y.2012-13 Was Issued On 25.09.2018 To The Assessee By The Assessing Officer (In Short “Ao”) & In Response To The Same, The Assessee Had Filed E-Return Of Income For The A.Y. 2012-13 On 17.08.2019 In Declaring Total Income Of Rs.14,53,440/-. :-3-:

Section 132Section 142Section 142(1)Section 143(2)Section 153A

pursuant to the search or requisition. However, instead of the earlier regime of block assessment whereby it was only the undisclosed income of the block period that was assessed, section 153A of the Act seeks to assess the total income for the assessment year, which is clear from the first ... employee in-charge of the bar. He then proceeded to finalise the block assessment under Section 158BB of the I.T. Act for the block period of five years from 1996-97 to 2000-01. The Appellate Tribunal, in an appeal preferred by the assessee, found that the statements recorded from

Jothi Narayanan, Chennai vs. DCIT, Central Circle-2(2), Chennai

ITA 2569/CHNY/2025[2011-12]Status: DisposedITAT Chennai09 Mar 2026AY 2011-12

Bench: This Tribunal.

Section 132Section 142Section 142(1)Section 143(2)Section 153A

pursuant to the search or requisition. However, instead of the earlier regime of block assessment whereby it was only the undisclosed income of the block period that was assessed, section 153A of the Act seeks to assess the total income for the assessment year, which is clear from the first ... employee in-charge of the bar. He then proceeded to finalise the block assessment under Section 158BB of the I.T. Act for the block period of five years from 1996-97 to 2000-01. The Appellate Tribunal, in an appeal preferred by the assessee, found that the statements recorded from

Jsp Projects (P) Ltd, Delhi vs. DCIT Central Circle - 13, Delhi

In the result appeal of the assessee in ITA number 3646/Del/2025 and

ITA 3647/DEL/2025[2021-22]Status: DisposedITAT Delhi09 Mar 2026AY 2021-22

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

Section 127(2)Section 153ASection 153CSection 63Section 65B

searched person on 14/2/2022. In this regard, it is submitted that in respect of the assessment proceedings under section 153C of the Act, the block period of six assessment years has to be reckoned from the date on which the seized material is received by the Assessing Officer having jurisdiction ... Singh. The aforesaid legal position also stood reiterated by the Supreme Court in Vikram Sujitkumar Bhatia. The submission of the respondents, therefore, that the block periods would have to be reckoned with reference to the date of search can neither be countenanced nor accepted. E. The reckoning

Jsp Projects (P) Ltd, Delhi vs. DCIT Central Circle - 13, Delhi

In the result appeal of the assessee in ITA number 3646/Del/2025 and

ITA 3646/DEL/2025[2020-21]Status: DisposedITAT Delhi09 Mar 2026AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

Section 127(2)Section 153ASection 153CSection 63Section 65B

searched person on 14/2/2022. In this regard, it is submitted that in respect of the assessment proceedings under section 153C of the Act, the block period of six assessment years has to be reckoned from the date on which the seized material is received by the Assessing Officer having jurisdiction ... Singh. The aforesaid legal position also stood reiterated by the Supreme Court in Vikram Sujitkumar Bhatia. The submission of the respondents, therefore, that the block periods would have to be reckoned with reference to the date of search can neither be countenanced nor accepted. E. The reckoning

Jsp Projects (P) Ltd, Delhi vs. DCIT Central Circle -13, Delhi

In the result appeal of the assessee in ITA number 3646/Del/2025 and

ITA 3645/DEL/2025[2019-20]Status: DisposedITAT Delhi09 Mar 2026AY 2019-20

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

Section 127(2)Section 153ASection 153CSection 63Section 65B

searched person on 14/2/2022. In this regard, it is submitted that in respect of the assessment proceedings under section 153C of the Act, the block period of six assessment years has to be reckoned from the date on which the seized material is received by the Assessing Officer having jurisdiction ... Singh. The aforesaid legal position also stood reiterated by the Supreme Court in Vikram Sujitkumar Bhatia. The submission of the respondents, therefore, that the block periods would have to be reckoned with reference to the date of search can neither be countenanced nor accepted. E. The reckoning

Jsp Projects (P) Ltd, Delhi vs. DCIT Central Circle - 13, Delhi

In the result appeal of the assessee in ITA number 3646/Del/2025 and

ITA 3644/DEL/2025[2016-17]Status: DisposedITAT Delhi09 Mar 2026AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

Section 127(2)Section 153ASection 153CSection 63Section 65B

searched person on 14/2/2022. In this regard, it is submitted that in respect of the assessment proceedings under section 153C of the Act, the block period of six assessment years has to be reckoned from the date on which the seized material is received by the Assessing Officer having jurisdiction ... Singh. The aforesaid legal position also stood reiterated by the Supreme Court in Vikram Sujitkumar Bhatia. The submission of the respondents, therefore, that the block periods would have to be reckoned with reference to the date of search can neither be countenanced nor accepted. E. The reckoning

Jsp Projects (P) Ltd, Delhi vs. DCIT Central Circle - 13, Delhi

In the result appeal of the assessee in ITA number 3646/Del/2025 and

ITA 3643/DEL/2025[2015-16]Status: DisposedITAT Delhi09 Mar 2026AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

Section 127(2)Section 153ASection 153CSection 63Section 65B

searched person on 14/2/2022. In this regard, it is submitted that in respect of the assessment proceedings under section 153C of the Act, the block period of six assessment years has to be reckoned from the date on which the seized material is received by the Assessing Officer having jurisdiction ... Singh. The aforesaid legal position also stood reiterated by the Supreme Court in Vikram Sujitkumar Bhatia. The submission of the respondents, therefore, that the block periods would have to be reckoned with reference to the date of search can neither be countenanced nor accepted. E. The reckoning

Assistant Commissioner of Income Tax, Central Circle-2, Patna vs. Patna Iron Pvt. Ltd., Patna

In the result, the appeals of the assessee are allowed and appeal of the Revenue is dismissed

ITA 373/PAT/2025[2020-21]Status: DisposedITAT Patna26 Feb 2026AY 2020-21

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Appellant) (Respondent) Pan No. Aafcp2484B Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Respondent) (Appellant) Sushil Kumar Kanodia N-601, Profesor Colony, Acit, Central Circle-2 Chitragupta Nagar, Kanakrbagh, Vs. Patna, Bihar Patna-800020, Bihar (Appellant) (Respondent) Pan No. Agypk0702D Assessee By : Shri Manish Rastogi, Ar Revenue By : Md. A.H. Chowdhary, Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 26.02.2025

For Appellant: Shri Manish Rastogi, ARFor Respondent: Md. A.H. Chowdhary, DR
Section 132Section 143(2)Section 143(3)Section 153ASection 153C

been made under section 153C of the Act and not under the normal provisions of the Act as the assessment year fell under the block period of six assessment years as defined in the first proviso to subclause (b) of section 153C(1) of the Act. The ld AR submitted ... year of search would be the next assessment year in which the satisfaction note was recorded. Therefore the assessment year fell within the block period of six years and the assessment ought to have been completed under section 153C of the Act and the assessment completed under section

Patna Iron Pvt. Ltd., Patna vs. ACIT, Central Circle-2, Patna

In the result, the appeals of the assessee are allowed and appeal of

ITA 332/PAT/2025[2020-21]Status: DisposedITAT Patna26 Feb 2026AY 2020-21

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

For Appellant: Shri Manish Rastogi, ARFor Respondent: Md. A.H. Chowdhary, DR
Section 132Section 143(2)Section 143(3)Section 153ASection 153C

been made under section 153C of the Act and not under the normal provisions of the Act as the assessment year fell under the block period of six assessment years as defined in the first proviso to subclause (b) of section 153C(1) of the Act. The Id AR submitted ... year of search would be the next assessment year in which the satisfaction note was recorded. Therefore the assessment year fell within the block period of six years and the assessment ought to have been completed under section 153C of the Act and the assessment completed under section

Sushil Kumar Kanodia, Patna vs. ACIT, Central Circle-2, Patna

In the result, the appeals of the assessee are allowed and appeal of the Revenue is dismissed

ITA 237/PAT/2025[2017-18]Status: DisposedITAT Patna26 Feb 2026AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Appellant) (Respondent) Pan No. Aafcp2484B Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Respondent) (Appellant) Sushil Kumar Kanodia N-601, Profesor Colony, Acit, Central Circle-2 Chitragupta Nagar, Kanakrbagh, Vs. Patna, Bihar Patna-800020, Bihar (Appellant) (Respondent) Pan No. Agypk0702D Assessee By : Shri Manish Rastogi, Ar Revenue By : Md. A.H. Chowdhary, Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 26.02.2025

For Appellant: Shri Manish Rastogi, ARFor Respondent: Md. A.H. Chowdhary, DR
Section 132Section 143(2)Section 143(3)Section 153ASection 153C

been made under section 153C of the Act and not under the normal provisions of the Act as the assessment year fell under the block period of six assessment years as defined in the first proviso to subclause (b) of section 153C(1) of the Act. The ld AR submitted ... year of search would be the next assessment year in which the satisfaction note was recorded. Therefore the assessment year fell within the block period of six years and the assessment ought to have been completed under section 153C of the Act and the assessment completed under section

Society for Advancement in Education, Mussoorie vs. ITO Exemption Dehradun, Dehradun

In the result, appeals of the assessee are allowed

ITA 220/DDN/2025[2011-12]Status: DisposedITAT Dehradun18 Feb 2026AY 2011-12

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

Section 143Section 143(3)Section 147Section 148Section 151Section 158

black Assessment- Search was conducted at residential and business premises of Assessee and notice for block assessment u/s. 158-BC was issued- For block period, returns were filed that were processed u/s. 143 (1)- However, notice u/s. 148 was issued by AO, on basis of certain reasons recordedAssessee objected

Society for Advancement in Education, Mussoorie vs. ITO Exemption Word Dehradun, Dehradun

In the result, appeals of the assessee are allowed

ITA 219/DDN/2025[2010-11]Status: DisposedITAT Dehradun18 Feb 2026AY 2010-11

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

Section 143Section 143(3)Section 147Section 148Section 151Section 158

black Assessment- Search was conducted at residential and business premises of Assessee and notice for block assessment u/s. 158-BC was issued- For block period, returns were filed that were processed u/s. 143 (1)- However, notice u/s. 148 was issued by AO, on basis of certain reasons recordedAssessee objected

Society for Advancement in Education, Mussoorie vs. ITO Exemption Word Dehradun, Dehradun

In the result, appeals of the assessee are allowed

ITA 218/DDN/2025[2009-10]Status: DisposedITAT Dehradun18 Feb 2026AY 2009-10

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

Section 143Section 143(3)Section 147Section 148Section 151Section 158

black Assessment- Search was conducted at residential and business premises of Assessee and notice for block assessment u/s. 158-BC was issued- For block period, returns were filed that were processed u/s. 143 (1)- However, notice u/s. 148 was issued by AO, on basis of certain reasons recordedAssessee objected

Nitinbhai Popatbhai Savani, Surat vs. DCIT, Central Cirle 2, Surat

In the result, both the appeals of the assessee are allowed

ITA 791/SRT/2025[2014-15]Status: DisposedITAT Surat17 Feb 2026AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 132Section 143(3)Section 153ASection 153CSection 153C(1)Section 263

which the seized material is handed over to the Assessing Officer having jurisdiction over such other person. Accordingly, for the purpose of computing the block period of six assessment years under section 153C, the relevant date in the present case is 31.03.2022. ITA Nos. 790 & 791/SRT/2025 Nareshbhai Babubhai Savani/ Nileshbhai ... other person, as opposed to the year of search which constitutes the basis for an assessment under Section 153A of the Act. Thus, the block period for the proceedings under Section 153C of the Act has to be computed from the date of receipt of books of accounts or documents

Nareshbhai Babubhai Savani, Surat vs. DCIT Central Circle 2, Surat

In the result, both the appeals of the assessee are allowed

ITA 790/SRT/2025[2014-15]Status: DisposedITAT Surat17 Feb 2026AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 132Section 143(3)Section 153ASection 153CSection 153C(1)Section 263

which the seized material is handed over to the Assessing Officer having jurisdiction over such other person. Accordingly, for the purpose of computing the block period of six assessment years under section 153C, the relevant date in the present case is 31.03.2022. ITA Nos. 790 & 791/SRT/2025 Nareshbhai Babubhai Savani/ Nileshbhai ... other person, as opposed to the year of search which constitutes the basis for an assessment under Section 153A of the Act. Thus, the block period for the proceedings under Section 153C of the Act has to be computed from the date of receipt of books of accounts or documents

Goal Oriented Trade Link Pvt. Ltd., Kolkata vs. ITO, Ward 2(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2576/KOL/2025[2013-2014]Status: DisposedITAT Kolkata17 Feb 2026AY 2013-2014

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 143(2)Section 147Section 148Section 14ASection 158Section 250

provides for enquiry and assessment. The said provision reads "that the assessing officer shall proceed to determine the undisclosed income of the Block period in the manner laid down in Section 158 BB and the provisions of Section 142, sub- section (2) and (3) of Section 143, Section ... Accordingly, we conclude even for the purpose of Chapter XIV-B of the Act, for the determination of undisclosed income for a block period under the provisions of Section 158 BC, the provisions of Section 142 and sub-sections (2) and (3) of Section 143 are applicable and no assessment

Assistant Commissioner of Income Tax, Central Circle, Bareilly vs. Ankur Anand, Bareilly

Appeals of the Department stand dismissed

ITA 337/LKW/2025[2015-16]Status: DisposedITAT Lucknow13 Feb 2026AY 2015-16

Bench: Shri Sudhanshu Srivastava & Shri Nikhil Choudharyit(Ss) A Nos.336 & 337/Lkw/2025 Assessment Years: 2014-15 & 2015-16 Acit, Central Circle, Bareilly Vs. Ankur Anand Kamla Nehru Marg, Civil Lines, 148 Civil Lines, Bareilly, Bareilly, Bareilly-243001. Bareilly-243001. Tan/Pan:Agppa4219C (Appellant) (Respondent) It(Ss)A No.334/Lkw/2025 Assessment Year:2015-16 Acit, Central Circle, Bareilly Vs. Mohit Anand Kamla Nehru Marg, Civil Lines, 148 Civil Lines, Bareilly, Bareilly, Bareilly-243001. Bareilly-243001. Tan/Pan:Abupa3002H (Appellant) (Respondent)

For Appellant: Shri Neeraj Kumar, CIT (DR)For Respondent: Shri Rakesh Garg, Advocate
Section 10(38)Section 132Section 143(3)Section 153ASection 68

pursuant to the search or requisition. However, instead of the earlier regime of block assessment whereby; it was only the undisclosed income of the block period that was assessed, section 153A of the Act seeks to assess the total income for the assessment year, which is clear from the first