153 C satisfaction must be specific

The ITAT, Delhi, by its order dated 24 July 2026, quashed assessments made under Section 153C of the Income-tax Act, holding that the limitation period for a person other than the searched person must be computed from the date the seized material is handed over to the jurisdictional Assessing Officer. The Tribunal further held that a common satisfaction notecovering multiple assessment years without year-wise satisfaction is legally defective and vitiates the entire proceedings.