Deputy Commissioner of Income Tax v. Sunil Kumar Sharma
168 Taxmann.com 77Supreme Court of India2024#4459 most cited
What is Deputy Commissioner of Income Tax v. Sunil Kumar Sharma authority for?
Proceedings initiated under Section 153C of the Income Tax Act are invalid if the Assessing Officer fails to record a satisfaction note indicating that the materials seized pertain to the assessee and have a bearing on the determination of their total income. A single, combined satisfaction note for multiple assessment years without year-wise income attribution is insufficient.
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judgments rely on this decision, according to BharatTax’s citation analysis of 366,315 Indian tax judgments — from 2025 to 2026.
Also referred to as
DCIT vs Sunil Kumar Sharma · section 153C · section 153A · satisfaction note · block period · dumb documents · search and seizure · assessment procedure · section 132(4) · section 153C(1) · section 153D