Search under s. 132 was conducted in the case of the searched person and certain electronic data and materials were relied upon to initiate proceedings under s. 153C against the assessees. The assessees challenged the jurisdiction under s. 153C and contended that electronic data could not be treated as “books of account” prior to amendment by the Finance Act, 2022; that provisions of ss. 65A, 65B and 66 of the Indian Evidence Act, 1872 were not complied with; and that the assessments were barred by limitation. Dismissing the writ petitions on jurisdiction and limitation, the Court held that assessment proceedings before the AO are quasi-judicial and not judicial proceedings; therefore, strict rules of evidence under the Indian Evidence Act, 1872 including ss. 65A, 65B and 66 have no application. The definition of “books and books of accounts” in s. 2(12A) uses the expression “includes” and has wide amplitude. The amendment by the Finance Act, 2022 inserting “electronic form”, “digital form” and printouts thereof is clarificatory in nature, intended to align the provision with technological developments, and is therefore retrospective. Even prior to amendment, data stored in electronic media such as hard disks, pen drives, etc., constituted books of account. For the purpose of limitation under the third proviso to s. 153B(1), the date of recording of satisfaction note is to be treated as the deemed date of handing over of seized material to the AO of the other person, even where the AO of the searched person and the other person is the same. There is no statutory time-limit for issuance of satisfaction note; assessments completed within twelve months from the end of the financial year in which such handing over is deemed to have taken place were within time. However, on facts, since unexplained income had been added in the hands of both directors, the impugned orders were quashed to that limited extent and matters were remanded for fresh exercise. (AYs. 2016-17 to 2021-22)