HON’BLE SUPREME COURT · SOURCE-REVIEWED NOTE
Commissioner of Income Tax 14 v. Jasjit Singh
Civil Appeal No. 6566 of 2023 / Connected Civil Appeal Nos. 6567, 6568 and 6589 of 2023
2023 INSC 882; [2023] 13 S.C.R. 706 ·
153C(1) · 153A
Sources & disclosures includedDownload original judgment / order
Two-judge bench · S. Ravindra Bhat, J. · Aravind Kumar, J.
01 · Facts of the case
The Revenue appealed four Delhi High Court outcomes concerning section 153C proceedings against persons other than the searched assessee. The example described a February 2009 search of the Kouton group, with notices to the other assessees on different later dates. They argued that the relevant period ran by reference to forwarding or receipt of material by their own officers; the Revenue sought to relate it back to the original search.
Source: reported supreme court judgment / paragraphs 1-6 / PDF pages 2, 3
02 · Discussion by the Hon’ble Court
The Court rejected the Revenue’s argument that the section 153C proviso operated only for abatement. It read the provision as also determining the date from which the six-year period was reckoned for the other person. Adopting the approach in SSP Aviation, it reasoned that relation back to the original search, despite delay in handing material to the other person’s officer, could impose disproportionate record-preservation consequences on a person not searched. The relevant statutory reference was receipt of the material by the officer having jurisdiction over that other person.
Source: reported supreme court judgment / paragraphs 7-10 / PDF pages 3, 4, 5, 6, 7
03 · Judicial decision
The Supreme Court found no merit in the Revenue’s appeals and dismissed them without costs.
Source: reported supreme court judgment / paragraphs 11 / PDF pages 7
04 · Outcome / in whose favour
In whose favour: Assessees
Revenue appeals dismissed; no costs
Lookback-date interpretation decided for the section 153C proceedings in issue
No individual assessment-year schedule is supplied. The judgment must be matched to the applicable historical provision; it is not a blanket statement covering every subsequently amended search or block-assessment regime.
Source: reported supreme court judgment / paragraphs 11 / PDF pages 7
05 · AKHB REVIEW POINT
Keep separate evidence of the search date, satisfaction and transfer records, and actual receipt by the other person’s jurisdictional officer. Do not automatically substitute the original search date or the date of notice for the statutory receipt trigger. Before calculating the years, verify the governing version and transitional provisions, particularly where later amendments change the framework.
Source: reported supreme court judgment / paragraphs 7-10 / PDF pages 3, 4, 5, 6, 7
Source & verification
Download original judgment / order · Open cited source rendition
Identified source rendition: 7 PDF pages; SHA-256 5eca3b102b79d488eb8a9f9450b4fe1fae8ca715a6dc9567daf6703110986e54. Original bytes preserved.
- Paragraph 3 prints section154A in the historical narrative and paragraph6 prints section153(1); the controlling analysis concerns section153C. These apparent source cross-reference errors are not converted into new propositions.
- Paragraph7 reproduces a statutory extract containing later wording; the note does not certify it as the exact consolidated text for every historical case in the batch.
- Specific assessment years are not enumerated in the common judgment. No years inferred from the search or notice dates.
- No individual author is stated in the reviewed judicial text; not inferred from bench order.
Statutory scope
Version-specific 1961 Act search-assessment reasoning. Later amendments, later judicial treatment and 2025 Act mapping are not certified.
Later treatment
Source checked 2026-10-04. Subsequent appeals, review proceedings, stays, reversals and later judicial treatment have not been comprehensively checked. This note is not a citator status certificate.
Page references identify the supplied PDF; paragraph references identify the judgment unless stated otherwise.
Identified source links
- reported supreme court judgment — PDF 7 pages
SHA-256: 5eca3b102b79d488eb8a9f9450b4fe1fae8ca715a6dc9567daf6703110986e54
Coverage, AI disclosure & professional disclaimer
Selected Supreme Court income-tax decisions and procedural orders checked against their identified sources. This collection is not exhaustive. The research catalogue has 2,569 indexed PDF assets, including alternate copies and incidental matches; that is not a count of unique or reviewed judgments. Historical and unreported coverage remains open.
AI-assisted research checked against the identified source. Extraction, interpretation or omission errors remain possible. Source review does not mean independent approval by a practising professional. Verify every material statement against the complete original judgment.
General research information only; not legal or tax advice, a certified judgment or a substitute for the full order. Applicability depends on facts, assessment year, statutory version and jurisdiction. Subsequent treatment is unverified unless a note expressly identifies the sources checked. Downloading does not create a professional engagement. Obtain case-specific advice before reliance.
The official 1961–2025 structural correspondence does not establish that a precedent applies under the new Act. Verify the enacted wording, commencement and transitional provisions separately.