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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

Jai Shankar Maheshwari, Delhi vs. DCIT, Central Circle-31, New Delhi, Delhi

In the result, the appeal of the assessee is allowed

ITA 1183/DEL/2024[2021-22]Status: DisposedITAT Delhi06 Aug 2025AY 2021-22

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2021-22] Shri Jai Shankar Vs Dcit, Maheshwari, B-14, 2Nd Floor, Central Circle-31, Preet Vihar, Delhi-110092. New Delhi Pan-Aaupm3199E Appellant Respondent Appellant By Dr.Rakesh Gupta, Adv. Respondent By Shri Om Parakash, Sr.Dr Date Of Hearing 14.05.2025 Date Of Pronouncement 06.08.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 31.01.2024 Of Ld. Commissioner Of Income Tax (A)-30, New Delhi [“Ld.Cit(A)”] In Appeal No.10146/2020-21 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 30.12.2022 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2020-21. 2. Brief Fact Of The Case Are That The Assessee Is An Individual, Having Income From Salary & Interest Income & Filed His Return Of Income On 10.01.2022, Declaring Income Of Inr 5,46,580/-. The Assessment Was Selected For Scrutiny By Way Of Issue Of Notice On 30.06.2022 & After Considering The Submissions Of The Assessee & Also Placing Reliance On The Material Found During The Course Of Search Carried Out On M/S. Jainco Ltd. On 06.01.2021, An Addition Of Inr 62,00,000/- Is Made To The Total Income Of The Assessee By Holding That The Same As Undisclosed Sales Consideration Received In Addition To The Agreed Consideration Received On The Sale Of 50% Of Shares In The Property At G-174, 2Nd Floor, Preet Vihar, New Delhi-110092. 3. Against This Order, An Appeal Filed By The Assessee Before Ld.Cit(A) Wherein The Assessee Has Challenged The Assessment Order On Merits Of The Additions Which Has Been Dismissed By The Ld.Cit(A) In Terms Of Impugned Order Dated 31.01.2024. 4. Aggrieved By The Said Order, The Assessee Is In Appeal Before Tribunal Wherein Following Grounds Of Appeal Are Taken:-

Section 143(3)Section 153CSection 250Section 54

case of CIT vs. Jasjit Singh, 458 ITR 437 (SC). 5. Thus, the year under consideration, i.e., AY 2021-22 falls within the block period of assessment to be framed w/s 153C of the Act whereas the Id. AO has completed this assessment u/s 143(3) of the Act based