Tribunal held that the search was conducted on the K group of cases on November 9, 2011. The impounded documents had been received by the AO on August 29, 2013. The satisfaction u/s. 153C had been recorded on October 3, 2013. The AO passed the assessment order u/s. 153B(1)(b) considering the AY 2012-13 to be the year of search. However, the first proviso to S.153C of the Act provides that the six assessment years for which assessments or reassessments could be made u/s. 153C would have to be construed with reference to the date of handing over of the assets or documents to the AO of the assessee. Therefore, the AY 2014-15 would be the year of search and the six assessment years u/s.153C of Act in the case of assessee would be assessment years 2008-09 to 2013-14. However, the AO had not issued any notice u/s.153C before initiating the proceedings against the assessee. The amendment in S.153C by the Finance Act, 2017, with effect from April 1, 2017 to the effect that the block period for the person in respect of whom the search was conducted as well as the “other person” would be the same six assessment years immediately preceding the year of search was prospective in nature. The AO, therefore, should have framed the assessment u/s.153C in the case of the assessee and at the time of initiating the proceeding against the assessee, issued notice u/s. 153C which had not been done in this case. The issue of notice u/s. 153C was mandatory and a condition precedent for taking action against the assessee u/s. 153C. Accordingly the assessment is illegal and bad in law. (AY .2012 – 2013)