SARVO TECHNOLOGIES LTD,DELHI vs. DCIT,CENTRAL CIRCLE-19, DELHI

ITA 1719/DEL/2025Status: DisposedITAT Delhi17 February 2026AY 2019-20Bench: SHRI C.N. PRASAD (Judicial Member), SHRI M. BALAGANESH (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that a consolidated satisfaction note recorded for multiple assessment years is bad in law and void ab initio, leading to a fundamentally flawed assumption of jurisdiction. Consequently, the assessment framed based on such a note is also invalid.

What were the facts?

The assessee filed an appeal against the order of the CIT(A)/NFAC for AY 2019-20. The core issue revolves around the validity of a consolidated satisfaction note recorded by the AO for initiating proceedings u/s 153C, which was then used to frame assessment orders u/s 153C/143(3). The assessee contended that this consolidated satisfaction note was bad in law as it lacked application of mind and was not year-wise.

What were the issues?

The primary issue was whether a consolidated satisfaction note recorded by the AO for initiating proceedings under Section 153C of the Income Tax Act, 1961, for multiple assessment years, is valid.

Which sections of the Income-tax Act were involved?

Section 153C,Section 143(3),Section 153D

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Income Tax Appellate Tribunal, DELHI BENCH, ‘G’: NEW DELHI

Before: SHRI C.N. PRASAD & SHRI M. BALAGANESH

Hearing: 14.01.2026Pronounced: 17.02.2026

PER C.N. PRASAD, JM, This appeal is filed by the assessee against the order of the Ld.Commissioner of Income Tax (Appeals)/NFAC dated 24.01.2025 for the A.Y. 2019-20. 2. The assessee has raised following grounds of appeal : A) That Ld CIT-A vide impugned order passed us 250 dated 24.01.2025erred in not quashing the impugned assessment order passed u/s 153C/143(3) dated 13.02.2024 which is founded on unlawful, invalid and illegal impugned reopening action u/s 153C of 1961 Act (vide juri ictional notice dated 24.04.2023)

B) That Ld CIT-A vide impugned order passed us 250 dated 24.01.2025erred in not quashing the impugned assessment order passed u/s 153C/143(3) dated 13.02.2024 which is founded on invalid satisfaction note recorded

The order continues below.

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