Search and seizure action on  Sarthav Infra Pvt Ltd was conducted on December 04 , 2014 . The information was received by the Assessing Officer on March 16, 2018 , i.e  AY. 2018 19 ). The notice under section 153C was issued on April 04 , 2018 .  Therefore six years prior to AY. 2018 -19 would be the period between AY. 2012 -13 to 2017 -18  , therefore , AY. 2018 -19 falls beyond the period of six years  and hence the proceedings are time barred . On appeal the CIT(A) held that the date of information received was 31 -3 -2018 is to be considered . The AY. 2011 -12  is beyond the period of six assessment years but within period of 10 years from the AY. In which the documents pertaining to the appellant have been received . Accordingly the dismissed the ground of limitation . On appeal , the Tribunal held that the AO had no jurisdiction to initiate  proceeding under section 153C of the Act for the AY. 2011-12 . Search was conducted before the amendment and also satisfaction note for the assessee  being a non searched party in AY. 2018 -19 .  Search  was conducted before the Finance Act , 2017 , power to assess block period of ten years could not be attracted in case of a search which had taken place prior to 1-4-2017 .  Accordingly , the    order passed under section 153C r. w.s 143 (3) of the Act was beyond permissible  of six years .  (ITA No. 4024 /Mum/ 2024 / 4512 / Mum/ 2024 dt 20 -12 -2024  .Followed PCIT v. Karina Air Lines International Ltd (ITA No. 690/ 2023 dated 2-8 -2024 ) (2024) 165 Taxmann.com 421 ( Delhi)( HC) ( AY. 2011 -12 )