ORDER

Yashwant Varma, J.

1. These three writ petitions pertaining to Assessment Year[AY] 2014-15 [W.P.(C) 4268/2024], AY 2015-16 [W.P.(C) 4265/2024], and AY 2016-17 [W.P.(C) 4264/2024], lay challenge to the initiation of proceedings under Section 153C of the Income Tax Act, 1961[Act] and thus impugn the notice dated 07 March 2023 referable to that provision. The petitioner, in addition, also impugns the orders dated 22 September 2023 as well as 01 March 2024 and 06 March 2024 passed by the respondents disposing of various objections which came to be submitted by the petitioner. For the sake of convenience, reference to facts and the position of material before us would be as appearing on W.P.(C) 4268/2024 being Item 93 on our board when we reserved orders.

2. The Section 153C action is based on searches which were conducted upon four individuals in April, 2019. According to the writ petitioner, on the basis of the material which was gathered in the course of those searches, the Assessing Officer[AO] of the searched persons also drew corresponding Satisfaction Notes for initiation of proceedings against the petitioner in terms of Section 153C of the Act on various dates the details whereof are set out in a tabular form as under:

Sr. No.Date of supply of satisfaction notesDate of satisfaction noteParticularsRecorded by whomAssessment Yearsi)30.6.20236.3.2023 Common satisfaction noteDeputy Commissioner of Income Tax, Central Circle-19, New Delhi (AO of the Assessee) 2014-15 to 2020-21ii) 26.9.202319.2.2023/20.02.2023 4 separate satisfaction notes recorded by AO of the searched person namely Praveen Kakkar, R.K. Miglani and Others group Deputy Commissioner of Income Tax, Central Circle-19, New Delhi (AO of searched person) 2014-15 to 2020-21iii) 26.9.202320.2.2023 Satisfaction notes recorded by AO of the searched person namely M/s Megha Engineering and Infrastructure Ltd. (MEIL group) Deputy Commissioner of Income Tax, Central Circle-19, New Delhi (AO of searched person) 2014-15 to 2020-21

3. Dr. Singhvi, learned senior counsel appearing in support of the instant writ petitions has raised the following submissions in support of the challenge to the initiation of action under Section 153C. Dr. Singhvi submitted that in terms of the impugned notices, the respondent seeks to undertake an assessment pertaining to AYs' 2014-15 to 2020-21. It was his submission that the assessment which is proposed to be undertaken for AYs 2014-15, 2015-16 and 2016-17 would be barred by the period of limitation as raised by virtue of the First Proviso to Section 153C of the Act. It was his contention that assessment under Section 153C of the Act could have at best covered the period of AYs' 2017-18 to 2020-21 and the three additional AYs namely 2014-15, 2015-16 and 2016-17 would be barred by limitation. The aforesaid submission proceeds on the premise that in light of the satisfaction recorded, the action under Section 153C of the Act could have extended only to six AYs' and that period undisputedly terminating on AY 2017- 18.

4. The aforenoted submission additionally proceeds on the basis that since the AO had failed to invoke Section 153A, the ten permissible block assessment years which could be opened up by virtue of the definition of "relevant assessment year" would not apply. It was the submission of Dr. Singhvi that in the absence of the AO having alluded to the Fourth Proviso of Section 153A and having recorded satisfaction of income exceeding INR 50 lakhs having possibly escaped assessment for each of the relevant AY or AYs' would constitute a sufficient ground for the impugned notices and proceedings being quashed.

5. It was also the submission of Dr. Singhvi that Section 153C obliges the AO to make specific reference to the incriminating material that may have been found in respect of each of the AYs' in respect of which proceedings under Section 153C are proposed to be initiated. According to learned senior coun

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