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“satisfaction note”

Search & SeizureSection 153CSection 153C2,598 judgments

The decision most relied on for satisfaction note is CIT v. RRJ Securities Ltd. (380 ITR 612), cited in 689 judgments on BharatTax.

Leading authorities on satisfaction note

CIT v. RRJ Securities Ltd.
380 ITR 612 · 2016 · High Court
689
citing judgments

Completed assessments can be interfered with under Section 153A or 153C only on the basis of incriminating material unearthed during the search, necessitating a direct correlation between the discovered material and the power to assess or reopen concluded assessments.

CIT v. Calcutta Knitwears
362 ITR 673 · 2014 · Supreme Court
528
citing judgments

The recording of a satisfaction note by the Assessing Officer is a jurisdictional prerequisite for assessments under Section 153C, and the six-year limitation period for such assessments is reckoned from the date this satisfaction is recorded.

ARN Infrastructure India Ltd. v. Asstt. CIT
394 ITR 569 · 2017 · High Court
282
citing judgments

For initiating proceedings under Section 153C, seized documents must be incriminating and specifically relate to the assessment years for which assessments are reopened. A document relevant only for one year cannot be used to reopen other assessment years without being incriminating for those years.

PCIT v. Ojjus Medicare (P) Ltd.
465 ITR 101 · 2024 · High Court
277
citing judgments

For assessments under Section 153C, the commencement point for calculating the six or ten assessment year block period is the date of issuing the Section 153C notice, or the date of the satisfaction note/handing over of books, as clarified by the first proviso to Section 153C(1).

DCIT v. Sunil Kumar Sharma
159 Taxmann.com 179 · 2024 · High Court
269
citing judgments

Loose sheets of paper containing jottings, not shown to be part of regularly maintained books of accounts, do not constitute incriminating material for initiating assessment under section 153C. The satisfaction note required for 153C proceedings must specify the assessment year to which the alleged incriminating material belongs.

Pepsico India Holdings (P) Ltd. v. ACIT
370 ITR 295 · 2015 · High Court
249
citing judgments

Section 153C of the Income-tax Act is invoked only when it is established that seized documents do not belong to the searched person, or if the searched person disclaims them; the satisfaction note must specifically indicate this fact.

Manish Maheshwari v. ACIT
289 ITR 341 · 2007 · Supreme Court
237
citing judgments

A block assessment proceeding under section 158BD is illegal if the procedure laid down in section 153C is not followed. The provisions of section 153C are similar to section 158BD in block assessment proceedings.

Pepsi Foods (P.) Ltd. v. Asstt. CIT
367 ITR 112 · 2014 · High Court
225
citing judgments

For assessments under Section 153C, a specific satisfaction note by the Assessing Officer of the person searched, recorded prior to initiating proceedings, is a jurisdictional prerequisite, rendering its absence void. The approval function under Section 153D is administrative and does not require elaborate reasoning.

Judgments citing satisfaction note

Polisetty Somasundaram, Guntur vs. Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 178/VIZ/2023[2018-19]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2018-19

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

definition of Asset as per the Explanation 2 of section 153A(1) though there were no such deposits in bank account as per the satisfaction note of the Assessing Officer. The Ld. CIT(A) ought to have held that the cash balance treated by the Assessing Officer as an Asset ... satisfaction note does not come under the ambit of the definition of Asset as per Explanation 2 of section 153A(1) and consequently ought to have held that the issue of notice U/s. 153A is invalid and the Assessment is bad in law. 4. On the facts

Polisetty Somasundaram, Guntur vs. Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 177/VIZ/2023[2017-18]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

definition of Asset as per the Explanation 2 of section 153A(1) though there were no such deposits in bank account as per the satisfaction note of the Assessing Officer. The Ld. CIT(A) ought to have held that the cash balance treated by the Assessing Officer as an Asset ... satisfaction note does not come under the ambit of the definition of Asset as per Explanation 2 of section 153A(1) and consequently ought to have held that the issue of notice U/s. 153A is invalid and the Assessment is bad in law. 4. On the facts

Polisetty Somasundaram, Guntur vs. Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 176/VIZ/2023[2016-17]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

definition of Asset as per the Explanation 2 of section 153A(1) though there were no such deposits in bank account as per the satisfaction note of the Assessing Officer. The Ld. CIT(A) ought to have held that the cash balance treated by the Assessing Officer as an Asset ... satisfaction note does not come under the ambit of the definition of Asset as per Explanation 2 of section 153A(1) and consequently ought to have held that the issue of notice U/s. 153A is invalid and the Assessment is bad in law. 4. On the facts

Polisetty Somasundaram, Guntur vs. Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 175/VIZ/2023[2015-16]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2015-16

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

definition of Asset as per the Explanation 2 of section 153A(1) though there were no such deposits in bank account as per the satisfaction note of the Assessing Officer. The Ld. CIT(A) ought to have held that the cash balance treated by the Assessing Officer as an Asset ... satisfaction note does not come under the ambit of the definition of Asset as per Explanation 2 of section 153A(1) and consequently ought to have held that the issue of notice U/s. 153A is invalid and the Assessment is bad in law. 4. On the facts

Polisetty Somasundaram, Guntur vs. Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 174/VIZ/2023[2014-15]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2014-15

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

definition of Asset as per the Explanation 2 of section 153A(1) though there were no such deposits in bank account as per the satisfaction note of the Assessing Officer. The Ld. CIT(A) ought to have held that the cash balance treated by the Assessing Officer as an Asset ... satisfaction note does not come under the ambit of the definition of Asset as per Explanation 2 of section 153A(1) and consequently ought to have held that the issue of notice U/s. 153A is invalid and the Assessment is bad in law. 4. On the facts

Polisetty Somasundaram, Guntur vs. Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 173/VIZ/2023[2013-14]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2013-14

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

definition of Asset as per the Explanation 2 of section 153A(1) though there were no such deposits in bank account as per the satisfaction note of the Assessing Officer. The Ld. CIT(A) ought to have held that the cash balance treated by the Assessing Officer as an Asset ... satisfaction note does not come under the ambit of the definition of Asset as per Explanation 2 of section 153A(1) and consequently ought to have held that the issue of notice U/s. 153A is invalid and the Assessment is bad in law. 4. On the facts

Polisetty Somasundaram, Guntur vs. Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 172/VIZ/2023[2012-13]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2012-13

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

definition of Asset as per the Explanation 2 of section 153A(1) though there were no such deposits in bank account as per the satisfaction note of the Assessing Officer. The Ld. CIT(A) ought to have held that the cash balance treated by the Assessing Officer as an Asset ... satisfaction note does not come under the ambit of the definition of Asset as per Explanation 2 of section 153A(1) and consequently ought to have held that the issue of notice U/s. 153A is invalid and the Assessment is bad in law. 4. On the facts

Rakesh Kumar Aggarwal, Delhi vs. ITO, Ward-40(3), New Delhi

In the result, the appeal of the assessee is thus allowed

ITA 699/DEL/2020[2009-10]Status: DisposedITAT Delhi17 Aug 2023AY 2009-10

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia

For Appellant: Shri Amit Goyal, CAFor Respondent: Shri Atiq Ahmed, Sr.DR
Section 143(3)Section 147Section 148Section 148(2)Section 151Section 234B

completed under Section 143(3) is barred by limitation and is void. I.T.A. No.699/Del/2020 2 Assessing officer has not applied his mind in recording satisfaction note for re-opening the assessment. It is further submitted that non-application of mind by the superior authorities while giving approval for re-opening

Raju Mohan Gurnani, Navi Mumbai vs. DCIT Central Cirle - 5(2), Mumbai

In the result, all the appeals of the assessee are partly allowed

ITA 2092/MUM/2021[2016-17]Status: DisposedITAT Mumbai31 Jul 2023AY 2016-17
Section 131Section 132Section 143(3)Section 153CSection 23(4)(b)

course of hearing (alongwith copy to the assessee). Hence, assessment was rightly completed u/s.153C.  The assessment is u/s. 153C and a copy of the satisfaction note recorded by the AO before the issue of notice was given to the assessee (placed at Pg 59-60 of the assessee's paper ... pertinent to take note of pages 15, 28, 61 etc which have also been specifically mentioned in Para 1 of the satisfaction note. Pgs 15 & 28 clearly show that cash is being received by 'mummy' ji ie. the assessee, evident from the document itself and various statements recorded during

Raju Mohan Gurnani, Navi Mumbai vs. DCIT Central Cirle - 5(2), Mumbai

In the result, all the appeals of the assessee are partly allowed

ITA 2091/MUM/2021[2015-16]Status: DisposedITAT Mumbai31 Jul 2023AY 2015-16
Section 131Section 132Section 143(3)Section 153CSection 23(4)(b)

course of hearing (alongwith copy to the assessee). Hence, assessment was rightly completed u/s.153C.  The assessment is u/s. 153C and a copy of the satisfaction note recorded by the AO before the issue of notice was given to the assessee (placed at Pg 59-60 of the assessee's paper ... pertinent to take note of pages 15, 28, 61 etc which have also been specifically mentioned in Para 1 of the satisfaction note. Pgs 15 & 28 clearly show that cash is being received by 'mummy' ji ie. the assessee, evident from the document itself and various statements recorded during

Raju Mohan Gurnani, Navi Mumbai vs. DCIT Central Cirle - 5(2), Mumbai

In the result, all the appeals of the assessee are partly allowed

ITA 2090/MUM/2021[2014-15]Status: DisposedITAT Mumbai31 Jul 2023AY 2014-15
Section 131Section 132Section 143(3)Section 153CSection 23(4)(b)

course of hearing (alongwith copy to the assessee). Hence, assessment was rightly completed u/s.153C.  The assessment is u/s. 153C and a copy of the satisfaction note recorded by the AO before the issue of notice was given to the assessee (placed at Pg 59-60 of the assessee's paper ... pertinent to take note of pages 15, 28, 61 etc which have also been specifically mentioned in Para 1 of the satisfaction note. Pgs 15 & 28 clearly show that cash is being received by 'mummy' ji ie. the assessee, evident from the document itself and various statements recorded during

Jayton Trading Pvt. Ltd., Kolkata vs. Dy. Commissioner of Income Tax (Central)-2, Raipur

In the result, appeal of the assessee is allowed

ITA 65/RPR/2021[2012-13]Status: DisposedITAT Raipur31 Jul 2023AY 2012-13

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.65/Rpr/2021 (Assessment Year: 2012-2013) Jayton Trading Private Limited, Vs Dcit (Central)-2, Raipur 15, Crooked Lane, 1St Floor, Hare Street, Kolkata Pan No. :Aaacj 6659 B (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri Jehangir D. Mistry, Sr. Advocate, Shri Madhur Agrawal, Advocate Shri Praveen Khandelwal & Praveen Goyal, Cas राज"व क" ओर से /Revenue By : Smt. Ila M. Parmar, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 29/05/2023 घोषणा क" तार"ख/Date Of Pronouncement : 31 /07/2023 आदेश / O R D E R Per Arun Khodpia, Am : The Assessee Has Filed This Appeal Against The Order Passed By The Cit(A)-3, Bhopal, Dated 06.07.2021 For The Assessment Year 2012-2013, On The Following Grounds :- 1. That On The Facts & In The Circumstances Of The Case & In Law, The Order Dated 06/07/2021 Passed U/S 250 Of The Act & The Assessment Order Passed U/S 144 R.W.S. 147 Of The Act Dated 30/12/2019 Are Illegal & Void Ab Initio. 2. That On The Facts & In The Circumstances Of The Case & In Law, The First Appellate Authority Erred In Not Confirming That The Notice Issued U/S 148 Of The Act Dated 28/03/2019 Is Bad In Law. 2.1 That On The Facts & In The Circumstances Of The Case & In Law, The First Appellate Authority Erred In Not Holding That The Notice Issued U/S 148 Of The Act Dated 28/03/2019 Is Time Barred By Limitation In View Of First Proviso To Section 147 Of The Act. 2.2 That On The Facts & In The Circumstances Of The Case & In Law, The First Appellate Authority Erred In Confirming The Reason Recorded U/S 148(2) Of The Act Though The Same Is Only A Change Of Opinion On Account Of Borrowed Satisfaction Without Application Of Mind By The Assessing Officer.

For Appellant: Shri Jehangir D. Mistry, Sr. AdvocateFor Respondent: Smt. Ila M. Parmar, CIT-DR
Section 143(3)Section 144Section 147Section 148Section 148(2)Section 250Section 68

Rashi Steel and power Ltd. Such inconsistency in the reasons recoded was demonstrated by the Ld AR by drawing our attention to copies of satisfaction note for issue of notice u/s 153C for AY 2013-14 to 2019-20 to the assessee company dated 22.07.2021 (paper book page ... unsecured loan, provide by Shri Suresh Agarwal through various shell/jamakhrchi companies managed and controlled by him and his employees, though, as per the satisfaction note u/s 153C, Ld AO has recorded that the assessee company was used by Shri Suresh Kumar Agarwal to provide accommodation entries to the RKTC Group

DCIT, Central Circle-1, Gurgaon vs. Jethmal Mehta, New Delhi

In the result, appeals of the Revenue for AYs

ITA 8987/DEL/2019[2014-15]Status: DisposedITAT Delhi19 Jul 2023AY 2014-15
Section 153ASection 153A(1)Section 153CSection 68

respectively. Page 2 of 20 ITA Nos.8985 to 8887/Del/2019 C.O. Nos. 160 to 162/Del/2022 DCIT vs. Jethmal Mehta “i) The AO has recorded his satisfaction note that incriminating documents seized possession of Sh. Rakesh Yadav and Sh. Rajbir Goyat reveals that Sh. Jethmal Mehta had en into various cash transactions ... amended by the Finance Act, 2015 w.e.f. 01.06.2015. Being procedural provisions, these will apply to all the proceedings u/s 153C initiated after 01.06.2015. Also satisfaction note in the instant case was recorded on 18.02.2016. As per substituted section 153C proceedings u/s 153C can be initiated on the basis of satisfaction

DCIT, Central Circle-1, Gurgaon vs. Jethmal Mehta, New Delhi

In the result, appeals of the Revenue for AYs

ITA 8986/DEL/2019[2013-14]Status: DisposedITAT Delhi19 Jul 2023AY 2013-14
Section 153ASection 153A(1)Section 153CSection 68

respectively. Page 2 of 20 ITA Nos.8985 to 8887/Del/2019 C.O. Nos. 160 to 162/Del/2022 DCIT vs. Jethmal Mehta “i) The AO has recorded his satisfaction note that incriminating documents seized possession of Sh. Rakesh Yadav and Sh. Rajbir Goyat reveals that Sh. Jethmal Mehta had en into various cash transactions ... amended by the Finance Act, 2015 w.e.f. 01.06.2015. Being procedural provisions, these will apply to all the proceedings u/s 153C initiated after 01.06.2015. Also satisfaction note in the instant case was recorded on 18.02.2016. As per substituted section 153C proceedings u/s 153C can be initiated on the basis of satisfaction

DCIT, Central Circle-1, Gurgaon vs. Jethmal Mehta, New Delhi

In the result, appeals of the Revenue for AYs

ITA 8985/DEL/2019[2012-13]Status: DisposedITAT Delhi19 Jul 2023AY 2012-13
Section 153ASection 153A(1)Section 153CSection 68

respectively. Page 2 of 20 ITA Nos.8985 to 8887/Del/2019 C.O. Nos. 160 to 162/Del/2022 DCIT vs. Jethmal Mehta “i) The AO has recorded his satisfaction note that incriminating documents seized possession of Sh. Rakesh Yadav and Sh. Rajbir Goyat reveals that Sh. Jethmal Mehta had en into various cash transactions ... amended by the Finance Act, 2015 w.e.f. 01.06.2015. Being procedural provisions, these will apply to all the proceedings u/s 153C initiated after 01.06.2015. Also satisfaction note in the instant case was recorded on 18.02.2016. As per substituted section 153C proceedings u/s 153C can be initiated on the basis of satisfaction

Macro Proprieties Private Limited, M 28 Income Tax Colony Tonk Road Jaipur vs. DCIT Central Circle 2, Lic Building Jaipur

In the result, the appeals of the assessee are allowed

ITA 174/JPR/2023[2013-2014]Status: DisposedITAT Jaipur17 Jul 2023AY 2013-2014

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;djvihy la-@ITA No.174 TO 177/JP/2023 fu/kZkj.ko"kZ@AssessmentYear : 2013-14 TO 2016-17 M/s. Macro Properties Pvt. Ltd.M-28, Income Tax Colony, Tonk Road Jaipur cuke Vs. The DCIT Central Circle-2 LIC Building, Jaipur LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAFCM 3633 D vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksjls@Assesseeby : Shri C.M. Agarwal, CA jktLo dh vksjls@Revenue by: Shri JameshKurian, CI

For Appellant: Shri C.M. Agarwal, CAFor Respondent: Shri JameshKurian, CIT
Section 153CSection 50C(1)Section 69

taking up the case of the assessee u/s. 153C of the Act. 5. The bench noted that there is no discussion to the satisfaction note or finding of any incriminating material in the order of the assessment, therefore, in the course hearing the bench directed the ld. AO through ... demonstrate as to the content of the satisfaction note if any before issue of notice u/s. 153C of the Act. The satisfaction note so recorded by the ld. AO as submitted by the ld. DR is reproduced here in below: Record Satisfaction (Stage 1) [Satisfaction remarks for recommending the case

Satya Pal, Gurgaon vs. ITO, Gurgaon

In the result all the three appeals of the assessees are partly allowed, as indicated above

ITA 3024/DEL/2017[2010-11]Status: DisposedITAT Delhi13 Jul 2023AY 2010-11

Bench: Shri Shamim Yahya & Shri Challa Nagendra Prasadआ.अ.सं .I.T.A No. 3024/Del/2017 िनधा"रण वष"/Assessment Year: 2010-11 Shri Satya Pal, Income Tax Officer, बनाम S/O. Late Maha Singh, Ward : 4 (1) Vs. Vill. & P.O. Nakhrola, Tehsil Gurgaon. Manesar, Distt. Gurgaon, Haryana – 122 001. Pan No. Aabpy6152A A N D आ.अ.सं .I.T.A No. 3022/Del/2017 िनधा"रण वष"/Assessment Year: 2010-11 Shri Satyabir Singh, Income Tax Officer, बनाम S/O. Late Maha Singh, Ward : 4 (1) Vs. Vill. & P.O. Nakhrola, Tehsil Gurgaon. Manesar, Distt. Gurgaon, Haryana – 122 001. Pan No. Aacpy7890A A N D आ.अ.सं .I.T.A No. 3023/Del/2017 िनधा"रण वष"/Assessment Year: 2010-11 Shri Rati Ram, Income Tax Officer, बनाम S/O. Late Maha Singh, Ward : 4 (1) Vs. Vill. & P.O. Nakhrola, Tehsil Gurgaon. Manesar, Distt. Gurgaon, Haryana – 122 001. Pan No. Aaopy3440Q अपीलाथ"/ Appellants ""थ"/ Respondents

For Appellant: Shri K. Sampath, Advocate; &
Section 143(3)Section 147Section 234ASection 253Section 54B

Income-tax Act the Act) to the assessee (page 52 of the paper book). The precursor to this notice was the satisfaction note recorded by the Assessing Officer placed at pages 53-54 of the paper book where the note mentions the status of the assessee as an individual ... Income-tax Act (the Act) to the assessee (page 81 of the paper book). The precursor to this notice was the satisfaction note recorded by the AO placed at pages 82-83 of the paper book where the note mentions the status of the assessee as an individual

Rati Ram, Gurgaon vs. ITO, Gurgaon

In the result all the three appeals of the assessees are partly allowed, as indicated above

ITA 3023/DEL/2017[2010-11]Status: DisposedITAT Delhi13 Jul 2023AY 2010-11

Bench: Shri Shamim Yahya & Shri Challa Nagendra Prasadआ.अ.सं .I.T.A No. 3024/Del/2017 िनधा"रण वष"/Assessment Year: 2010-11 Shri Satya Pal, Income Tax Officer, बनाम S/O. Late Maha Singh, Ward : 4 (1) Vs. Vill. & P.O. Nakhrola, Tehsil Gurgaon. Manesar, Distt. Gurgaon, Haryana – 122 001. Pan No. Aabpy6152A A N D आ.अ.सं .I.T.A No. 3022/Del/2017 िनधा"रण वष"/Assessment Year: 2010-11 Shri Satyabir Singh, Income Tax Officer, बनाम S/O. Late Maha Singh, Ward : 4 (1) Vs. Vill. & P.O. Nakhrola, Tehsil Gurgaon. Manesar, Distt. Gurgaon, Haryana – 122 001. Pan No. Aacpy7890A A N D आ.अ.सं .I.T.A No. 3023/Del/2017 िनधा"रण वष"/Assessment Year: 2010-11 Shri Rati Ram, Income Tax Officer, बनाम S/O. Late Maha Singh, Ward : 4 (1) Vs. Vill. & P.O. Nakhrola, Tehsil Gurgaon. Manesar, Distt. Gurgaon, Haryana – 122 001. Pan No. Aaopy3440Q अपीलाथ"/ Appellants ""थ"/ Respondents

For Appellant: Shri K. Sampath, Advocate; &
Section 143(3)Section 147Section 234ASection 253Section 54B

Income-tax Act the Act) to the assessee (page 52 of the paper book). The precursor to this notice was the satisfaction note recorded by the Assessing Officer placed at pages 53-54 of the paper book where the note mentions the status of the assessee as an individual ... Income-tax Act (the Act) to the assessee (page 81 of the paper book). The precursor to this notice was the satisfaction note recorded by the AO placed at pages 82-83 of the paper book where the note mentions the status of the assessee as an individual

Satyabir Singh Yadav, Gurgaon vs. ITO, Gurgaon

In the result all the three appeals of the assessees are partly allowed, as indicated above

ITA 3022/DEL/2017[2010-11]Status: DisposedITAT Delhi13 Jul 2023AY 2010-11

Bench: Shri Shamim Yahya & Shri Challa Nagendra Prasadआ.अ.सं .I.T.A No. 3024/Del/2017 िनधा"रण वष"/Assessment Year: 2010-11 Shri Satya Pal, Income Tax Officer, बनाम S/O. Late Maha Singh, Ward : 4 (1) Vs. Vill. & P.O. Nakhrola, Tehsil Gurgaon. Manesar, Distt. Gurgaon, Haryana – 122 001. Pan No. Aabpy6152A A N D आ.अ.सं .I.T.A No. 3022/Del/2017 िनधा"रण वष"/Assessment Year: 2010-11 Shri Satyabir Singh, Income Tax Officer, बनाम S/O. Late Maha Singh, Ward : 4 (1) Vs. Vill. & P.O. Nakhrola, Tehsil Gurgaon. Manesar, Distt. Gurgaon, Haryana – 122 001. Pan No. Aacpy7890A A N D आ.अ.सं .I.T.A No. 3023/Del/2017 िनधा"रण वष"/Assessment Year: 2010-11 Shri Rati Ram, Income Tax Officer, बनाम S/O. Late Maha Singh, Ward : 4 (1) Vs. Vill. & P.O. Nakhrola, Tehsil Gurgaon. Manesar, Distt. Gurgaon, Haryana – 122 001. Pan No. Aaopy3440Q अपीलाथ"/ Appellants ""थ"/ Respondents

For Appellant: Shri K. Sampath, Advocate; &
Section 143(3)Section 147Section 234ASection 253Section 54B

Income-tax Act the Act) to the assessee (page 52 of the paper book). The precursor to this notice was the satisfaction note recorded by the Assessing Officer placed at pages 53-54 of the paper book where the note mentions the status of the assessee as an individual ... Income-tax Act (the Act) to the assessee (page 81 of the paper book). The precursor to this notice was the satisfaction note recorded by the AO placed at pages 82-83 of the paper book where the note mentions the status of the assessee as an individual

Shri Avinash Nivrutti Bhosale, Pune vs. Dy CIT Central Cir-2(3), Mumbai

In the result, both the appeals filed by the assessee are allowed

ITA 531/MUM/2021[2010-11]Status: DisposedITAT Mumbai10 Jul 2023AY 2010-11

Bench: Shri Kuldip Singh & Shri Gagan Goyal & Shri Avinash Nivrutti Bhosale, 2, Abil House, Ganesh Khind Road, Range Hill Corner, Pune-411 007 ...... Appellant Vs. Dcit Cent. Cir 2(3) 8Th Floor, R. No. 803, Old Cgo Bldg, Pratistha Bhavan, M. K. Road, Mumbai-400 020 Pan – Abtpb8151F ..... Respondent

For Appellant: Shri Madhur Agarwal, Ld. ARFor Respondent: Smt. Shailja Rai, Ld. DR
Section 143(3)Section 153ASection 250

material in the hands of the assessee and merely relying on the statement of the third party and information declared before ITSC. From the satisfaction note recorded by the AO (as stated above) to initiate proceedings u/s 153A, he has recorded that he was satisfied that the income escaped