← All Phrases

“satisfaction note”

Search & SeizureSection 153CSection 153C2,598 judgments

DCIT, CENTRAL CIRCLE-14, NEW DELHI, JHANDEWALAN EXTN. vs. SHYAM SUNDER VERMA, MODEL TOWN-III

In the result, the appeal filed by the Department of Revenue is dismissed

ITA 8072/DEL/2025[2017-18]Status: DisposedITAT Delhi09 Apr 2026AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Vimal Kumardcit Vs. Shyam Sunder Verma Central Circle 14 R-66/2, Model Town-Iii New Delhi North West Delhi 110009 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acbpv 9328 D Appellant .. Respondent

For Appellant: Sh. Sandeep Goel, AdvFor Respondent: Ms. Monika Singh, CIT-DR
Section 127Section 132Section 142(1)Section 143(2)Section 143(3)Section 153BSection 153CSection 153DSection 250

153C of the Act. Hon'ble ITAT in its decision, dated 27.02.2025 held: “as in the case of the assessee also the satisfaction note for initiating the proceedings u/s 153C were recorded by the AO of the assessee on 10-10-2-2022 thus assessment year relevant for previous year

GAURAV VERMA,DELHI vs. DCIT, CENTRAL CIRCLE-8, DELHI

ITA 4456/DEL/2025[2019-20]Status: DisposedITAT Delhi20 Mar 2026AY 2019-20

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumar

For Appellant: Sh. Kamal K Jaitely, Adv. & Sh. SudhirFor Respondent: Ms. Pooja Swaroop, CIT(DR)
Section 132Section 132(4)Section 153CSection 153DSection 69A

liable to be quashed inasmuch as the AO assumed jurisdiction u/s. 153C on the basis of a single, consolidated and mechanical “satisfaction note” common for all the assessment years, without recording a proper, independent and case-specific satisfaction for each assessment year separately and without establishing any linkage of seized ... liable to be quashed inasmuch as the AO assumed jurisdiction u/s. 153C on the basis of a single, consolidated and mechanical “satisfaction note” common for all the assessment years, without recording a proper, independent and case-specific satisfaction for each assessment year separately and without establishing any linkage of seized

GAURAV VERMA,DELHI vs. DCIT, CENTRAL CIRCLE-8, DELHI

ITA 4455/DEL/2025[2018-19]Status: DisposedITAT Delhi20 Mar 2026AY 2018-19

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumar

For Appellant: Sh. Kamal K Jaitely, Adv. & Sh. SudhirFor Respondent: Ms. Pooja Swaroop, CIT(DR)
Section 132Section 132(4)Section 153CSection 153DSection 69A

liable to be quashed inasmuch as the AO assumed jurisdiction u/s. 153C on the basis of a single, consolidated and mechanical “satisfaction note” common for all the assessment years, without recording a proper, independent and case-specific satisfaction for each assessment year separately and without establishing any linkage of seized ... liable to be quashed inasmuch as the AO assumed jurisdiction u/s. 153C on the basis of a single, consolidated and mechanical “satisfaction note” common for all the assessment years, without recording a proper, independent and case-specific satisfaction for each assessment year separately and without establishing any linkage of seized

GAURAV VERMA,DELHI vs. DCIT, CENTRAL CIRCLE-8 DELHI, DELHI

ITA 4454/DEL/2025[2017-18]Status: DisposedITAT Delhi20 Mar 2026AY 2017-18

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumar

For Appellant: Sh. Kamal K Jaitely, Adv. & Sh. SudhirFor Respondent: Ms. Pooja Swaroop, CIT(DR)
Section 132Section 132(4)Section 153CSection 153DSection 69A

liable to be quashed inasmuch as the AO assumed jurisdiction u/s. 153C on the basis of a single, consolidated and mechanical “satisfaction note” common for all the assessment years, without recording a proper, independent and case-specific satisfaction for each assessment year separately and without establishing any linkage of seized ... liable to be quashed inasmuch as the AO assumed jurisdiction u/s. 153C on the basis of a single, consolidated and mechanical “satisfaction note” common for all the assessment years, without recording a proper, independent and case-specific satisfaction for each assessment year separately and without establishing any linkage of seized

KRISH PACKAGING PVT LTD,NEW DELHI vs. DCIT CENTRAL CIRCLE, NOIDA

ITA 3942/DEL/2019[2011-12]Status: DisposedITAT Delhi13 Mar 2026AY 2011-12

Bench: Shri Anubhav Sharma & Shri Naveen Chandrakrish Packaging Pvt. Ltd. Vs. Dcit, Central Circle F-11, Basement Green Sector -33, Noida Park, Extension , Uttar Pradesh – 201307 New Delhi – 110016 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aacck8980A Appellant .. Respondent

For Appellant: Sh. Salil Aggarwal, Sr. AdvFor Respondent: Sh. Dayainder Singh Sidhu, CIT
Section 143(3)Section 153CSection 69

proceedings initiated under section 153C of the Act are without satisfying the statutory pre - conditions envisaged under the Act, more specifically as no satisfaction note has been recorded prior to issuance of notice under section 153C of the Act and the impugned assessment proceeding is thus, without jurisdiction ... material which has been sustained by the ld. First Appellate Authority for which assessee is in appeal. 4. Ld. Counsel has primarily hit the satisfaction note alleging that the same is not in accordance with law as the same does not show as to how the allegedly recovered and seized

PAL MINERAL INDUSTRIES (P) LIMITED,HALDWANI vs. DC/ACIT, CENTRAL CIRCLE, HALDWANI, HALDWANI

ITA 106/DDN/2025[2013-2014]Status: DisposedITAT Dehradun12 Mar 2026AY 2013-2014

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 153ASection 153CSection 250

erred in upholding the validity of the proceedings under Section 153C, falling to appreciate that the Assessing Officer recorded a consolidated Satisfaction Note for multiple Assessment Years (AY 2011- n. to 16) instead of recording satisfaction for each Assessment Year separately. Ground No. 13 Because on the facts and circumstances ... erred in failing to appreciate that the proceedings under Section 153C are void ab initio and bad in law as the Satisfaction Note forming the basis of jurisdiction is undated and unsigned. Ground No. 14 Because on the facts and circumstances of the case

PAL MINERAL INDUSTRIES (P) LIMITED,HALDWANI vs. DC/ACIT, CENTRAL CIRCLE, HALDWANI, HALDWANI

ITA 105/DDN/2025[2014-2015]Status: DisposedITAT Dehradun12 Mar 2026AY 2014-2015

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 153ASection 153CSection 250

erred in upholding the validity of the proceedings under Section 153C, falling to appreciate that the Assessing Officer recorded a consolidated Satisfaction Note for multiple Assessment Years (AY 2011- n. to 16) instead of recording satisfaction for each Assessment Year separately. Ground No. 13 Because on the facts and circumstances ... erred in failing to appreciate that the proceedings under Section 153C are void ab initio and bad in law as the Satisfaction Note forming the basis of jurisdiction is undated and unsigned. Ground No. 14 Because on the facts and circumstances of the case

MOHAN PAL,HALDWANI, NAINITAL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HALDWANI, ACIT - DCIT, CENTRAL CIRCLE, HALDWANI

ITA 85/DDN/2024[2015-16]Status: DisposedITAT Dehradun12 Mar 2026AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 132Section 143(3)Section 153ASection 153A(1)Section 153CSection 250

erred in upholding the validity of the proceedings under Section 153C, falling to appreciate that the Assessing Officer recorded a consolidated Satisfaction Note for multiple Assessment Years (AY 2011-1240 16) instead of recording satisfaction for each Assessment Year separately. Ground No. 22 Because on the facts and circumstances ... erred in falling to appreciate that the proceedings under Section 153C are void ab initio and bad in law as the Satisfaction Note forming the basis of jurisdiction is undated and unsigned. Ground No. 23 Because on the facts and circumstances of the case

MOHAN PAL,HALDWANI, NAINITAL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HALDWANI, ACIT - DCIT, CENTRAL CIRCLE, HALDWANI

ITA 84/DDN/2024[2014-15]Status: DisposedITAT Dehradun12 Mar 2026AY 2014-15

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 132Section 143(3)Section 153ASection 153A(1)Section 153CSection 250

erred in upholding the validity of the proceedings under Section 153C, falling to appreciate that the Assessing Officer recorded a consolidated Satisfaction Note for multiple Assessment Years (AY 2011-1240 16) instead of recording satisfaction for each Assessment Year separately. Ground No. 22 Because on the facts and circumstances ... erred in falling to appreciate that the proceedings under Section 153C are void ab initio and bad in law as the Satisfaction Note forming the basis of jurisdiction is undated and unsigned. Ground No. 23 Because on the facts and circumstances of the case

MOHAN PAL,HALDWANI, NAINITAL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HALDWANI, ACIT-DCIT, CENTRAL CIRCLE, HALDWANI

ITA 83/DDN/2024[2013-14]Status: DisposedITAT Dehradun12 Mar 2026AY 2013-14

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 132Section 143(3)Section 153ASection 153A(1)Section 153CSection 250

erred in upholding the validity of the proceedings under Section 153C, falling to appreciate that the Assessing Officer recorded a consolidated Satisfaction Note for multiple Assessment Years (AY 2011-1240 16) instead of recording satisfaction for each Assessment Year separately. Ground No. 22 Because on the facts and circumstances ... erred in falling to appreciate that the proceedings under Section 153C are void ab initio and bad in law as the Satisfaction Note forming the basis of jurisdiction is undated and unsigned. Ground No. 23 Because on the facts and circumstances of the case

BALWANT LAXMANJI PUROHIT,MUMBAI vs. DCIT CENTRAL CIRCLE 4(2), MUMBAI

In the result, all the three appeal

ITA 8454/MUM/2025[2019-2020]Status: DisposedITAT Mumbai12 Mar 2026AY 2019-2020

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Arun Kanti Datta, CIT-DRFor Respondent: Mr. Bharat Kumar
Section 153CSection 250

document. Besides, incrementing document. Besides, he has not referred to any he has not referred to any incriminating material in incriminating material in the satisfaction note issued to the the satisfaction note issued to the Appellant. Appellant. 3. On the facts and circumstances of the case ... case, the CIT(A) erred in On the facts and circumstances of the case, the CIT(A) erred in holding that a combined satisfaction note is valid in the eyes holding that a combined satisfaction note is valid in the eyes holding that a combined satisfaction note is valid

BALWANT LAXMANJI PUROHIT,MUMBAI vs. DCIT CENTRAL CIRCLE 4(2), MUMBAI

In the result, all the three appeal

ITA 8453/MUM/2025[2018-2019]Status: DisposedITAT Mumbai12 Mar 2026AY 2018-2019

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Arun Kanti Datta, CIT-DRFor Respondent: Mr. Bharat Kumar
Section 153CSection 250

document. Besides, incrementing document. Besides, he has not referred to any he has not referred to any incriminating material in incriminating material in the satisfaction note issued to the the satisfaction note issued to the Appellant. Appellant. 3. On the facts and circumstances of the case ... case, the CIT(A) erred in On the facts and circumstances of the case, the CIT(A) erred in holding that a combined satisfaction note is valid in the eyes holding that a combined satisfaction note is valid in the eyes holding that a combined satisfaction note is valid

BALWANT LAXMANJI PUROHIT,MUMBAI vs. DCIT CENTRAL CIRCLE 4(2), MUMBAI

In the result, all the three appeal

ITA 8452/MUM/2025[2017-2018]Status: DisposedITAT Mumbai12 Mar 2026AY 2017-2018

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Arun Kanti Datta, CIT-DRFor Respondent: Mr. Bharat Kumar
Section 153CSection 250

document. Besides, incrementing document. Besides, he has not referred to any he has not referred to any incriminating material in incriminating material in the satisfaction note issued to the the satisfaction note issued to the Appellant. Appellant. 3. On the facts and circumstances of the case ... case, the CIT(A) erred in On the facts and circumstances of the case, the CIT(A) erred in holding that a combined satisfaction note is valid in the eyes holding that a combined satisfaction note is valid in the eyes holding that a combined satisfaction note is valid

GANESHARAM GALBARAM MALI ,MUMBAI vs. DCIT, CENTRAL CIRCLE 4(2), MUMBAI

In the result the appeals of the assessee bearing ITA No

ITA 8349/MUM/2025[2017-18]Status: DisposedITAT Mumbai12 Mar 2026AY 2017-18
Section 132Section 153CSection 250Section 69Section 69C

that such\ndenial violates the principles of natural justice, thereby rendering the assessment invalid.\n8.1 The AO have mentioned gist of allegation in the satisfaction note. In this regard, I have\nperused the show cause notice issued by the AO in many cases, where proceedings were\ninitiated on the similar

GANESHARAM GALBARAM MALI ,MUMBAI vs. DCIT CENTRAL CIRCLE 4(2), MUMBAI

In the result the appeals of the assessee bearing ITA No

ITA 8348/MUM/2025[2018-19]Status: DisposedITAT Mumbai12 Mar 2026AY 2018-19

Bench: Us.

For Appellant: Shri Bharat Kumar, CAFor Respondent: Shri Arun Kanti Datta (CIT DR)
Section 132Section 132(4)Section 153CSection 250Section 69C

that such denial violates the principles of natural justice, thereby rendering the assessment invalid. 8.1 The AO have mentioned gist of allegation in the satisfaction note. In this regard, I have perused the show cause notice issued by the AO in many cases, where proceedings were initiated on the similar

GANESHARAM GALBARAM MALI ,MUMBAI vs. DCIT CENTRAL CIRCLE 4(2), MUMBAI

In the result the appeals of the assessee bearing ITA No

ITA 8347/MUM/2025[2019-20]Status: DisposedITAT Mumbai12 Mar 2026AY 2019-20

Bench: Us.

For Appellant: Shri Bharat Kumar, CAFor Respondent: Shri Arun Kanti Datta (CIT DR)
Section 132Section 132(4)Section 153CSection 250Section 69C

that such denial violates the principles of natural justice, thereby rendering the assessment invalid. 8.1 The AO have mentioned gist of allegation in the satisfaction note. In this regard, I have perused the show cause notice issued by the AO in many cases, where proceedings were initiated on the similar

PADMA LOGISTICS PVT LTD,DELHI vs. DCIT, CENTRAL CIRCLE-5, NEW DELHI

In the result, the appeal of the Assessee is allowed

ITA 4938/DEL/2025[2015-16]Status: DisposedITAT Delhi11 Mar 2026AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshpadma Logistics Pvt. Ltd, Vs. Dcit, Gf-, P-14, Kalakaar Street, Central Circle-5, Burra Bazar, Kolkata, Wb Jhandewalan, Delhi (Appellant) (Respondent) Pan: Aahcp1175H

For Appellant: Shri Raj Kumar Gupta, CAFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 132Section 132ASection 143(3)Section 153A(1)Section 153C

which falls in assessment year 2019-20. During the course of his search, some documents relating / pertaining to Assessee was found. Hence, a satisfaction note under Section 153C of the Act was recorded by the learned AO of the Assessee on 25-6-2021, which falls in assessment year ... Admittedly, the satisfaction note was prepared by the learned AO of the Assessee for six preceding assessment years by assuming the search year as assessment year 2019-20 based on the year of search conducted on Shri Kshitij Lal. Accordingly, the revenue sought to initiate proceedings from assessment years

RICHMOND EDUCATIONAL SOCIETY,NOIDA vs. DCIT/ACIT CENTRAL CIRCLE, GHAZIABAD, GHAZIABAD

In the result, the appeal of the Assessee is allowed

ITA 4779/DEL/2025[2024-25]Status: DisposedITAT Delhi11 Mar 2026AY 2024-25
For Respondent: \nShri Gaurav Jain, Adv
Section 12ASection 132Section 143(3)Section 2(15)

nLearned PCIT in assuming jurisdiction based on reference made by the\nLearned Assessing Officer who had made such reference without\nrecording any satisfaction note as prescribed under the second proviso to\nsection 143(3) r.w.s.12AB(4)(b) of the Act.\nThe Ground No. 5 raised by the Assessee is challenging

ALOK & CO LLP,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

In the result, appeal filed by the assessee are partly allowed

ITA 2736/DEL/2025[2017-18]Status: DisposedITAT Delhi11 Mar 2026AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 153CSection 153DSection 65BSection 69A

case, the CIT(A) failed to appreciate the fact that the additions/disallowances made by the AO are beyond the scope of the satisfaction note. 13. On the facts and circumstances of the case and in law, the AO erred in making illegal additions and completing the assessment at income ... Court had upheld the decision of the ITAT, which had deleted the addition on the reason that the addition was not based on the satisfaction note prepared for the purposes of initiation of proceedings against the assessee u/s 153C of the ITA No. 2735 & 2736/Del/2025 Act. The so-called incriminating

ALOK & CO LLP,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

In the result, appeal filed by the assessee are partly allowed

ITA 2735/DEL/2025[2016-17]Status: DisposedITAT Delhi11 Mar 2026AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 153CSection 153DSection 65BSection 69A

case, the CIT(A) failed to appreciate the fact that the additions/disallowances made by the AO are beyond the scope of the satisfaction note. 13. On the facts and circumstances of the case and in law, the AO erred in making illegal additions and completing the assessment at income ... Court had upheld the decision of the ITAT, which had deleted the addition on the reason that the addition was not based on the satisfaction note prepared for the purposes of initiation of proceedings against the assessee u/s 153C of the ITA No. 2735 & 2736/Del/2025 Act. The so-called incriminating

Showing 1–20 of 2,598 · Page 1 of 130

...