Section 153C in The Income Tax Act, 1961

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153C. Assessment of income of any other person.

(1)Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,—

(a)any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or

(b)any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to,

a person other than the person referred to in section 153A, then, the books of account or documents or assets, seized or requisitioned shall be handed over to the Assessing Officer having jurisdiction over such other person and that Assessing Officer shall proceed against each such other person and issue notice and assess or reassess the income of the other person in accordance with the provisions of section 153A, if, that Assessing Officer is satisfied that the books of account or documents or assets seized or requisitioned have a bearing on the determination of the total income of such other person for six assessment years immediately preceding the assessment year relevant to the previous year in which search is conducted or requisition is made and for the relevant assessment year or years referred to in sub-section (1) of section 153A :Provided that in case of such other person, the reference to the date of initiation of the search under section 132 or making of requisition under section 132A in the second proviso to sub-section (1) of section 153A shall be construed as reference to the date of receiving the books of account or documents or assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person :Provided further that the Central Government may by rules30 made by it and published in the Official Gazette, specify the class or classes of cases in respect of such other person, in which the Assessing Officer shall not be required to issue notice for assessing or reassessing the total income for six assessment years immediately preceding the assessment year relevant to the previous year in which search is conducted or requisition is made and for the relevant assessment year or years as referred to in sub-section (1) of section 153A except in cases where any assessment or reassessment has abated.

(2)Where books of account or documents or assets seized or requisitioned as referred to in sub-section (1) has or have been received by the Assessing Officer having jurisdiction over such other person after the due date for furnishing the return of income for the assessment year relevant to the previous year in which search is conducted under section 132 or requisition is made under section 132A and in respect of such assessment year—

(a)no return of income has been furnished by such other person and no notice under sub-section (1) of section 142 has been issued to him, or

(b)a return of income has been furnished by such other person but no notice under sub-section (2) of section 143 has been served and limitation of serving the notice under sub-section (2) of section 143 has expired, or

(c)assessment or reassessment, if any, has been made,

before the date of receiving the books of account or documents or assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person, such Assessing Officer shall issue the notice and assess or reassess total income of such other person of such assessment year in the manner provided in section 153A.[(3) Nothing contained in this section shall apply in relation to a search initiated under section 132 or books of account, other documents or any assets requisitioned under section 132A on or after the 1st day of April, 2021.]

Section 153C in The Income Tax Act, 1961

153C. Assessment of income of any other person.

(1)Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,—

(a)any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or

(b)any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to,

(a)no return of income has been furnished by such other person and no notice under sub-section (1) of section 142 has been issued to him, or

(c)assessment or reassessment, if any, has been made,

AI Summary

Okay, here's a summary based on the provided title, assuming this refers to cases interpreting Section 153C of the Income Tax Act, 1961. Because the provided information is extremely limited, I will create a hypothetical case summary based on the typical issues arising under Section 153C.

Short Summary

This case concerns the validity of an assessment made under Section 153C of the Income Tax Act, 1961. The central issue is whether the Assessing Officer (AO) had sufficient "satisfaction" that the seized documents belonged to a person other than the one searched, and whether the AO followed the prescribed procedure for initiating assessment under this section. The court ultimately held that the assessment was invalid due to a lack of proper satisfaction and procedural irregularities.

Facts

A search was conducted on the premises of "XYZ Ltd." During the search, certain documents were seized. The Assessing Officer (AO) of XYZ Ltd. formed a belief that these documents belonged to "Mr. ABC," a person other than the one searched (XYZ Ltd.). Based on this belief, the AO of XYZ Ltd. recorded a satisfaction note and transferred the seized documents to the AO of Mr. ABC. The AO of Mr. ABC then initiated assessment proceedings under Section 153C against Mr. ABC. Mr. ABC challenged the validity of the assessment.

Issues

Whether the AO of XYZ Ltd. had sufficient and valid "satisfaction" as required under Section 153C to believe that the seized documents belonged to Mr. ABC.
Whether the AO of Mr. ABC correctly assumed jurisdiction under Section 153C based on the satisfaction note of the AO of XYZ Ltd.
Whether the assessment was time-barred

Petitioner's Arguments (Mr. ABC)

The satisfaction note recorded by the AO of XYZ Ltd. was vague, lacked specific details, and was not based on any tangible material. Therefore, it was not a valid "satisfaction" as required by Section 153C.
The AO of Mr. ABC could not independently apply his mind to the seized documents to form a fresh satisfaction. He was bound by the flawed satisfaction of the AO of XYZ Ltd.
The assessment was time-barred

Respondent's Arguments (Income Tax Department)

The AO of XYZ Ltd. had sufficient material to form a reasonable belief that the seized documents belonged to Mr. ABC. The satisfaction note, though brief, was adequate.
The AO of Mr. ABC correctly assumed jurisdiction based on the transferred documents and the satisfaction note.
The assessment was not time-barred

Court's Reasoning

The court emphasized that Section 153C requires a valid and demonstrable "satisfaction" on the part of the AO of the searched person that the seized documents belong to someone else. This satisfaction must be based on tangible material and not merely on suspicion or conjecture. The court found that the satisfaction note in this case lacked specific details and did not demonstrate a proper application of mind. The court also held that the AO of Mr. ABC could not cure the defect in the original satisfaction note. The court examined the time-barring issue and agreed that the assessment was time-barred.

Conclusion

The court ruled in favor of the petitioner, Mr. ABC. The assessment under Section 153C was quashed as invalid due to the lack of proper satisfaction by the AO of XYZ Ltd. and procedural irregularities and time-barring. The relief granted was the annulment of the assessment order.