JCIT(OSD), JHANDEWALAN vs. NARENDRA AGGARWAL, FARIDABAD

JCIT (OSD), JHANDEWALAN, vs. NARENDRA AGGARWAL, DELHI H.NO. 467, SECTOR-21-A, FARDIDABAD, HARYANA (PAN: AAGPA1441D) (APPELLANT) (RESPONDENT) ASSESSEE BY : Dr.Rakesh Gupta, Adv., Sh. Somil Agarwal, Adv., Saksham Agarwal, CA & Deepesh Garg, Adv. REVENUE BY : Ms. Amisha S. Gupt, CIT DR Date of Hearing : 04.11.2025 Date of Order : 19.12.2025 O R D E R PER SUDHIR KUMAR, JM :

This appeal is preferred by the Revenue against the order of ld. Commissioner of Income-tax (Appeals)-26, New Delhi (hereinafter referred to ‘Ld. CIT (A)’) dated 28.11.2024 for AY 2015-16.

6.2 The technical grounds are summarized as under. First, in the absence of any incriminating material found/seized during the course of search on a third party, no proceedings U/S.153C could have been initiated for A,Y 2015-16. Apparently, Appellant's contention is that the assessment is made on the basis of regular books of A/c on account of claim of short- term capital gains. Second, the assessment year under consideration i.e. AY 2015-16, being an unabated year, no proceeding under section 153C of the Act would be initiated without any incriminating material found/seized. Third, as per the satisfaction note, the purported AY 2016-17 and therefore, no proceeding under section 153C of the Act could be initiated as the said material does not have a bearing in determining the total income of the assessment year 2015-16. Fourth, as in this case a consolidated satisfaction note had been recorded for all the assessment years, it would vitiate entire assessment proceedings in view of the decision of Hon'ble Supreme Court in Sunil Kumar Sharma [2024] 165 taxmann.com 846 (SC).

6.3 The primary ground relating to validity of assumption of jurisdiction is that assessment under section 153C of the Act could be initiated only on the basis of incriminating document found and seized dunng the course of search action. Further, the assessment year under consideration being an unabated year, no proceeding under section 153C of the Act would be initiated without any incriminating material found/seized in view of Hon'ble Supreme court in the case of Abhisar Buildwell case. Appellant's contention is that the assessment is made on the basis of regular books of A/c.

6.4 Before delving into the legal grounds, it is essential to go through the facts and the legal provisions under section 153C of the Act. In the instant case, the proceeding under section 153C of the Act was initiated consequent to a search & seizure action conducted under section 132 of the Act in the case of Punet Kulthia on 08.03.2017 wherein certain documents/information pertaining to the appellant was found and seized. Thereafter, the AO of the searched person handed over the said seized AO of the appellant. Subsequently, the AO of the appellant recorded his satisfaction on 17 09.2021and issued notice under section 153C of the Act to the appellant on 09.10.2021. The assessment order was passed under section 153C read with section 143(3) of the Acton 27.12 2022.

Legal framework for initiation of proceeding under section 153C

6.5 Section 153C of the Act provides as under:

(1) Notwithstanding anything contained in section 139, section 147, section 148. section 149, section 151 and section 153. where the Assessing Officer is satisfied that.— (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to. a person other than the person referred to in section 153A. then, the books of account or documents or assets, seized or requisitioned shall be handed over to the Assessing Officer having jurisdiction over such other person and that Assessing Officer shall proceed against each such other person and issue notice and assess or reassess the income of the other person in accordance with the provisions of section 153A, if. that Assessing Officer is satisfied that the books of account or documents or assets seized or requisitioned have a bearing on the determination of the total income of such other person for six assessment years immediately preceding the assessment year relevant

Provided that in case of such other person the reference to the date of initiation of the search under section 132 or making of requisition under section 132A in the second proviso to sub-section (1) of section 153A shall be construed as reference to the date of receiving the books of account or documents or assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person.

Provided further that the Central Government may by rules made by it and published in the Official Gazette, specify the class or classes of cases in respect of such other person, in which the Assessing Officer shall not be required to issue notice for assessing or reassessing the total income for six assessment years immediately preceding the assessment year relevant to the previous year in which search is conducted or requisition is made and for the relevant assessment year or years as referred Io in sub-section (1) of section 153A except in cases where any assessment or reassessment has abated.

6.6 Further, section 153A of the Act provides that "153A Notwithstanding anything contained in section 139. section 147. section 148. section 149 section 151 and section 153. in the case of a person where a search is initialed under section 132 or books of account,

(a) issue notice to such person requiring him to furnish within such period, as may be specified in the notice, the return of income in respect of each assessment year falling within six assessment years and for the relevant assessment year or years referred to in clause (b) referred to in clause (b). in the prescribed form and verified in the prescribed manner and setting forth such other particulars as may be prescribed and the provisions of this Act shall, so far as may be, apply accordingly as if such return were a return required to be furnished under section 139; (b) assess or reassess the total income of six assessment years immediately preceding the assessment year relevant to the previous year in which such search is conducted or requisition is made: Provided that the Assessing Officer shall assess or reassess the total income in respect of each assessment year falling within such six assessment years: 6.7 A collective reading of the aforesaid provisions would provide the legal framework of application of section 153C of the Act where search is conducted before 01 04.2017 In the instant case the search action had taken place on 08.03.2017 In brief, in the case of person other than the searched person, assessment or reassessment under section 153C of the Act was not automatic unlike the case of searched person Such assessment or reassessment could take place only when firstly, the AO of searched person was satisfied that the seized assets/documents belong/pertain/relate to a person other than the searched person and AO of other person, and secondly, thereafter, the AO of such other person should also be satisfied that seized assets/ documents forwarded to him have being on the determination of total income of the other person for the year under consideration. Further, in view of the decision of Hon’ble Supreme Court in Sunil Kumar Sharma [2024] 165 taxmann.com 846 (SC) affirming the decision of and Delhi High Court, satisfaction note is required to be recorded under section 153C of the Act for each assessment year separately. Alternatively, the court has held that where a consolidated satisfaction note had been recorded for different assessment years, it would vitiate entire assessment proceedings. Assessing Officer of the such other person shall Issue notice to such person requiring him to furnish return of income in respect of each assessment year falling within six assessment years immediately preceding the assessment year relevant to the previous year in which search is conducted or requisition is made as per sub-section (1) of section 153A for assessing or reassessing the total income. As per first proviso to section 153C, in case of such other person, the reference to the date of initiation of the search or making of requisition shall be construed as reference to the date of receiving of such books of account or documents or assets by the jurisdictional AO. Therefore, for the purposes of section 153C, the date of search is not relevant Here, the date of receiving of books of account or documents or assets by the jurisdictional AO is the reference point for deciding the assessment years for which an assessment or reassessment is required to be made.

6.8 Further, notice under section 153C of the Act could be issued for only such assessment years being unabated/completed years in respect of which there was incriminating material in possession of this legal position has been settled by the Apex court in PCIT Vs Abhisar Build well (P.) Ltd [2023] 149 taxmann.com 399 (SC) and PCIT vs. S.S. Con Build (P.) Ltd. [2023] 151 taxmann.com 317 (SC). ln addition to the above, not only there should be incriminating matenal but those incriminating material would be havingbearing on the determination of total income for such years so as to initiate proceedings under section 153C of the Act This position of law is now settled by the Hon'ble Supreme Court in CIT v. Singhad Technical Education Society [TS-5145-SC-2017-0] and has been recently endorsed by Hon’ble Delhi High Court in the case of Saksham Commodities Limited in [TS- 5160-HC-2024(Delhi).

6.9 With this background, the case of the appellant is examined. The main ground is whether assumption of jurisdiction under section 153C of the Act would be legally sustainable when there was no incriminating material found/seized This position would be appreciated from the facts of the case Appellant had filed its original return of income under section 139(1) of the Act on 20-08-2015 declaring an Income of INR 6.20,97.150/-. Subsequently, the case of the appellant was selected for scrutiny through CASS for making inquiries on four issues including the Short- Term Capital Gain u/s 111 of the Act AO passed the assessment order under section 143(3) of the Act on 27.12.2017 wherein the returned income was accepted. Thereafter, the PCIT initiated the proceeding under section 263 of the Act and set aside the assessment order passed by the AO u/s 143(3) in terms of the provisions of section 263 of the Act and directed the AO to frame fresh assessment after considering the observations of PCIT in the order passed u/s 263 of the Act on 31-03- 2021. However, on appeal filed by the appellant before the Hon'ble Income Tax Appellate Tribunal (ITAT) against the order passed by the learned PCIT under Section 263 of the Act. the Hon'ble ITAT. Delhi Bench vide its order in dated 04.04.2022 had set aside the aforesaid order of PCIT passed under section 263 of the Act Subsequently, the Department went in appeal before the Hon’ble Delhi High Court against the order passed by Hon’ble ITAT and Hon'ble Delhi High Court upheld the stand of Hon'ble ITAT and decided the matter in appellant's favour in order dated 17-9-2024. In the meantime, another proceeding under section 153C of the Act was initiated on 09.10.2021 consequent to a search action conducted under section 132 of the Act in the case of Shri Puneet Kulthia on 08.03 2017.

The basis of initiation of this proceeding would be understood if one refers to the satisfaction note of the AO of the appellant (non-searched person). The satisfaction of AO of the appellant was submitted during the course of this appellate proceedings which is marked as pages 143 to 148 of the paper book The satisfaction note dated 17.09.2021 indicates a document In A-8 of panchanama dated 09.03.2017 which was found and seized from the premises of Puneet Kulthia containing certain communications through Apple phone between Puneet Kulthia and the appellant in respect of cash transactions The digital data were put in a consolidated manner as per the satisfaction note in page no.

148. This 07 12.2015 to 09 12.2015 pertaining to AY 2016-17. However, the assessment proceeding was completed under section 143(3) read with section 153C of the Act on 27.12 2022 where in addition of INR 4,65,02,946/- was made on account of unexplained cash credit u/s 68 of the Act in respect of transactions involving penny stock involving sale of shares of M/s K.D. Trend wear Limited and M/s Parnav Sports Academy Limited.

6.10 Apparently, the additions are emanated from the regular books of account maintained by the appellant. Alternatively, the additions have not been made on the basis of any incriminating material which is in form of certain cash transactions as evidenced from the satisfaction note. Therefore, in view of the Hon’ble Supreme court's decision in DCIT Vs. U. K. Paints (Overseas) Ltd. [2023] 150 taxmann.com 108 (SC), the decisions of jurisdictional High Court in CIT Vs Kabul Chawla(2016) 380 ITR 573(Delhi) etc., no proceeding could be initiated under section 153C of the Act in the absence of any incriminating documents Accordingly, this ground is allowed.

6.11 The second argument is that the incriminating material, if any pertains to financial year 2015-16 relating AY 2016-17 as evidenced from the satisfaction note of AO of the appellant discussed above As per the satisfaction note, the purported incriminating material is in respect of certain cash transactions for the period 7.12.2015 to 09.12.2015 relating to FY 2015-16 (AY 2016-17). As discussed above, the legal requirement to 153C of the Act is that such incriminating material should have a bearing on the determination of the total income of the assessee. Apparently, the cash transactions that are relating to the appellant pertain to AY 2016-17 and therefore, do not have a bearing on determination of total income of the appellant for A Y 2015- 16, Appeal No. 26/10621/2014-15 income of the appellant for AY 2015-16 Hence, notice issued under section 153C of the Act is contrary to the provisions of law. This issue has now been settled by Hon'ble Supreme Court in the case of CIT VS. SINGHAD TECHNICAL EDUCATION SOCIETY 397 ITR 344 (SC) wherein the Apex court has held that incriminating material seized must pertain to assessment years in question in order to assume jurisdiction to issue notice under section 153C of 1he Act Similar view has been taken by the Hon’ble Jurisdictional High Court in the case of Saksham Commodities Limited in [TS-5160-HC- 2024(Delhi)-0]. The Court has held that "the discovery of material likely to implicate the assessee and impact the assessment of total income for a particular AY was not intended to set off a chain reaction or a waterfall effect on all AYs' which could form part of the "relevant assessment year1”. The Court opined that mere existence of a power to assess or reassess the six Assessment Years ('AYs') immediately preceding the AY corresponding to the year of search or the "relevant assessment year" would not justify a sweeping or indiscriminate invocation of Section 153-C of the Act. The jurisdictional Assessing Officer ('AO') would have to firstly be satisfied that the material received was likely to havo a bearing on or impact the total income of years or years which may form part of the block of six or ten AYs’ and thereafter proceed to place the Further reliance may be made in the case of jurisdictional High Court in DEV TECHNOFAB LTD. Vs. DCIT [2024] 166 taxmann.com 514 (DHC) - Dtd.24.05.24. In view of the above legal position, the appellant succeeds on this ground of appeal. Accordingly, this ground on validity of assumption of jurisdiction is allowed.

6.12 The appellant's other ground is that the assessment year under consideration is an unabated year as neither any assessment proceeding was for this assessment year pending at the time of issue of notice under section 153C of the Act nor there was time available at the time issue of notice u/s 153C for issuance notice under section 143(2) of the Act. So, in the absence of any incriminating document, no proceeding under section 153C of the Act could have been initiated for this unabated Assessment Year. From the facts of the case, there is no dispute to the fact that the assessment year under consideration is an unabated/completed year. In such a situation, assumption of jurisdiction to initiate proceedings is held to be bad in law by the Hon'ble Supreme Court in the case of PCIT Vs Abhisar Build well (P.) Ltd [2023] 149 taxmann.com 399 (SC). The Hon'ble Supreme court in the aforesaid case had held that in respect of completed assessments/unabated assessments no addition can be made by Assessing Officer in absence of any incriminating material found during course of search under section 132 or requisition under section 132A of the Act. Similar view was taken by the jurisdictional High Court in the case of CIT VS. Kabul Chawla, 380 ITR (Delhi) 573. Further, the Hon’ble Supreme Court in another case In DCIT Vs. U. K. Paints (Overseas) Ltd. [2023] 150 taxmann.com 108 (SC), dated 25.04.23 has held, while confirming the decision of the High Court in setting aside the Assessment order that where no incriminating material was found in case of any of assessee either from assesses or from third party, the assessment made under section 153C of the Act is invalid. In the light of the above, the appellant succeeds on this ground as well.

6.13 Further, the appellant has also taken the ground that the satisfaction notes recorded by the AO before assuming the jurisdiction under section 153C of the Act is bad in law as it is a consolidated satisfaction note for all the assessment years and therefore, is contrary to the legal position settled by the Hon'ble Supreme Court in the case of Sunil Kumar Sharma (supra). In order to find out the factual position the satisfaction note produced as per page nos. 143 to 148 of the paper book was perused. Apparently, the satisfaction note in page no. 143 indicates that consolidated satisfaction has been made by the AO for all the relevant assessment years i.e. AY 2011-12 to AY 2017-18. Therefore, the facts of this case would be covered by the aforesaid decision of the Apex Court. For the sake of brevity, the Hon'ble Supreme Court in Sunil Kumar Shanna [2024] 165 taxmann.com 846 (SC) while affirming the decision of and Delhi High Court, had held that satisfaction note is required to be recorded under section 153C of the Act for each assessment year and where a consolidated satisfaction note had been recorded for different assessment years, it would vitiate entire assessment proceedings. Hence, the appellant would succeed also on this ground.

6.14 In view of the aforesaid discussions and by following the decisions of Hon'ble Supreme Court and the jurisdictional High Court as mentioned above, the appellant's grounds on legal validity of assumption of Jurisdiction are allowed.

6.15 As the appellant succeeds on these jurisdictional grounds, other grounds on legal validity on assumption jurisdiction as well as the substantive grounds on the quantum addition are not adjudicated at this stage being infructuous.

Thereafter, the AO of the searched person handed over the said seized document after recording the satisfaction to the AO of the assessee. Subsequently, the AO of the assessee recorded his satisfaction on 17 09.2021 and issued notice under section 153C of the Act to the appellant on 09.10.2021. The assessment order was passed under section 153C read with section 143(3) of the Acton 27.12 2022.

153A as under:-

“Section 153C of the Act provides as under: (2) Notwithstanding anything contained in section 139, section 147, section 148. section 149, section 151 and section 153. where the Assessing Officer is satisfied that.— (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to. a person other than the person referred to in section 153A. then, the books of account or documents or assets, seized or requisitioned shall be handed over to the Assessing Officer having jurisdiction over such other person and that Assessing Officer shall proceed against each such other person and issue notice and assess or reassess the income of the other person in accordance with the provisions of section 153A, if. that Assessing Officer is satisfied that the books of account or documents or assets seized or requisitioned have a bearing on the determination of the total income of such other person for six assessment years immediately preceding the assessment yer relevant to the previous year in which search is conducted or requisition is made and for the relevant assessment year or years referred to in sub- section (1) of section 153A.

Provided that in case of such other person the reference to the date of initiation of the search under section 132 or making of requisition under section 132A in the second proviso to sub-section (1) of section 153A shall be construed as reference to the date of receiving the books of account or documents or assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person.

Provided further that the Central Government may by rules made by it and published in the Official Gazette, specify the class or classes of cases in respect of such other person, in which the Assessing Officer shall not be required to issue notice for assessing or reassessing the total income for six assessment years immediately preceding the assessment year relevant to the previous year in which search is conducted or requisition is made and for the relevant assessment year or years as referred Io in sub-section (1) of section 153A except in cases where any assessment or reassessment has abated.

Further, section 153A of the Act provides that:

"153A Notwithstanding anything contained in section 139. section 147. section 148. section 149 section 151 and section 153. in the case of a person where a search is initialed under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May. 2003.The Assessing Officer shall—

(a) issue notice to such person requiring him to furnish within such period, as may be specified in the notice, the return of income in respect of each assessment year falling within six assessment years and for the relevant assessment year or years referred to in clause (b) referred to in clause (b). in the prescribed form and verified in the prescribed manner and setting forth such other particulars as may be prescribed and the provisions of this Act shall, so far as may be, apply accordingly as if such return were a return required to be furnished under section 139; (b) assess or reassess the total income of six assessment years immediately preceding the assessment year relevant to the previous year in which such search is conducted or requisition is made: Provided that the Assessing Officer shall assess or reassess the total income in respect of each assessment year falling within such six assessment years:”

6.2 On careful, consideration of the aforesaid provisions, it is seen that the said provisions would provide the legal framework of application of section 153C of the Act where search is conducted before 01.04.2017. However, in the instant case the search action had taken place on 08.03.2017. In the case of person other than the searched person, assessment or reassessment under section 153C of the Act was not automatic unlike the case of searched person. Such assessment or reassessment could take place only when firstly, the AO of searched person was satisfied that the seized assets/documents belong/pertain/relate to a person other AO of other person, and secondly, thereafter, the AO of such other person should also be satisfied that seized assets/ documents forwarded to him have being on the determination of total income of the other person for the year under consideration. Further, in view of the decision of Hon’ble Supreme Court in Sunil Kumar Sharma [2024] 165 taxmann.com 846 (SC) affirming the decision of and Delhi High Court, satisfaction note is required to be recorded under section 153C of the Act for each assessment year separately. Alternatively, the court has held that where a consolidated satisfaction note had been recorded for different assessment years, it would vitiate entire assessment proceedings. Assessing Officer of the such other person shall Issue notice to such person requiring him to furnish return of income in respect of each assessment year falling within six assessment years immediately preceding the assessment year relevant to the previous year in which search is conducted or requisition is made as per sub-section (1) of section 153A for assessing or reassessing the total income. As per first proviso to section 153C, in case of such other person, the reference to the date of initiation of the search or making of requisition shall be construed as reference to the date of receiving of such books of account or documents or assets by the jurisdictional AO. Therefore, for the purposes of section 153C, the date of search is not relevant here, the date of receiving of books of account or documents or assets by the jurisdictional AO is the reference point for deciding the assessment years for which an assessment or reassessment is required to be made. Also it is noted that notice under section 153C of the Act could be issued for only such assessment years being unabated/completed years in respect of which there was incriminating material in possession of this legal position as has been settled by the Apex court in PCIT Vs Abhisar Build well (P.) Ltd [2023] 149 taxmann.com 399 (SC) and PCIT vs. S.S.

Con Build (P.) Ltd. [2023] 151 taxmann.com 317 (SC). In addition to the above, not only there should be incriminating material but those incriminating material would be having bearing on the determination of total income for such years so as to initiate proceedings under section 153C of the Act. This position of law is now settled by the Hon'ble Supreme Court in CIT v. Singhad Technical Education Society [TS-5145-SC-2017-0] and has been endorsed by Hon’ble Delhi High Court in the case of Saksham Commodities Limited in [TS- 5160-HC- 2024(Delhi). The basis of initiation of this proceeding would be understood if one refers to the satisfaction note of the AO of the appellant (non-searched person). The satisfaction of AO of the assessee was placed before us with the Paper Book at pages 143 to 148 of the assessee’s paper book The satisfaction note dated 17.09.2021 indicates a document in A-8 of panchanama dated 09.03.2017 which was found and seized from the premises of Puneet Kulthia containing certain communications through Apple phone between Puneet Kulthia and the appellant in respect of cash transactions. The digital data were put in a consolidated manner as per the satisfaction note in page no.

6.3. The revenue’s other contention is that the assessment year under consideration is not an unabated year. However, it is noted that neither any assessment proceeding was for this assessment year pending at the time of issue of notice under section 153C of the Act nor there was time available at the time issue of notice u/s 153C for issuance notice under section 143(2) of the Act. So, in the absence of any incriminating document, no proceeding under section 153C of the Act could have been initiated for this unabated Assessment Year. From the facts of the case, there is no dispute to the fact that the assessment year under consideration is an unabated/completed year. It is observed that the instant AY 2015-16 is unabated assessment and hence in the absence of incriminating material for AY 2015-16, no addition could be made in 153C/153A assessment, in view of the decision in the case of PCIT vs. Abhisar Buildwell P Ltd. (2023) 454 ITR 212 (SC) and PCIT vs. UK Paints India P Ltd. (2025) 170 taxmann. In view of above, it is noticed that as per settled law that in the absence of any incriminating material found/seized during the course of search on a third party, no proceedings u/s. 153C could have been initiated for AY 2015-16. In this case assessment was made on the basis of regular books of A/c on account of claim of short-term capital gains. The proceeding under section 153C of the Act would be initiated without any incriminating material found/seized. As per the satisfaction note, the purported incriminating documents of cash transactions relate to AY 2016-17 and therefore, no proceeding under section 153C of the Act could be initiated as the said material does not have a bearing in determining the total income of the assessment year 2015-16. As in this case a consolidated satisfaction note had been recorded for all the assessment years, it would vitiate entire assessment proceedings in view of the decision of Hon'ble Supreme Court in Sunil Kumar Sharma [2024] 165 taxmann.com 846 (SC). The main ground relating to validity of assumption of jurisdiction is that assessment under section 153C of the Act could be initiated only on the basis of incriminating document found and seized during the course of search action. Further, the assessment year under consideration being an unabated year, no proceeding under section 153C of the Act would be initiated without any incriminating material found/seized in view of Hon'ble Supreme court in the case of Abhisar Buildwell case. Appellant's contention is that the assessment is made on the basis of regular books of A/c. Similar view was taken by the jurisdictional High Court in the case of CIT VS. Kabul Chawla, 380 ITR (Delhi) 573. Further, the Hon’ble Supreme Court in another case in DCIT Vs. U. K. Paints (Overseas) Ltd.

[2023] 150 taxmann.com 108 (SC), dated 25.04.23 has held, while confirming the incriminating material was found in case of any of assessee either from assesses or from third party, the assessment made under section 153C of the Act is invalid. In the light of the above, the revenue on this ground fails.

6.4. As regards, other contention relating to satisfaction notes recorded by the AO before assuming the jurisdiction under section 153C of the Act is concerned, it is a consolidated satisfaction note for all the assessment years and therefore, is contrary to the legal position settled by the Hon'ble Supreme Court in the case of Sunil Kumar Sharma (supra). In order to find out the factual position the satisfaction note produced as per page nos. 143 to 148 of the paper book was perused.

Apparently, the satisfaction note in page no. 143 indicates that consolidated satisfaction has been made by the AO for all the relevant assessment years i.e. AY 2011-12 to AY 2017-18. Therefore, the facts of this case would be covered by the aforesaid decision of the Apex Court. For the sake of brevity, the Hon'ble Supreme Court in Sunil Kumar Shanna [2024] 165 taxmann.com 846 (SC) while affirming the decision of and Delhi High Court, had held that satisfaction note is required to be recorded under section 153C of the Act for each assessment year and where a consolidated satisfaction note had been recorded for different assessment years, it would vitiate entire assessment proceedings. Hence, the Revenue fails on this ground.

7. Keeping in view of the aforesaid facts and circumstances, and respectfully following the aforesaid precedents, we are of the considered view that the Ld. CIT(A) has passed a well, reasoned order, which does not need any interference on our part, hence, we uphold the same. 8. In the result, the appeal filed by the Revenue is dismissed. Order pronounced in the open court on this 19th day of December, 2025.