“satisfaction note”

Sunrise F & B Restaurant Pvt Ltd, Delhi vs. ACIT, Central Circle-30, Delhi

In the result, assessment passed u/s 143(3) r

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

belong to the searched person but belongs to the assessee. Based on the above satisfaction, the case was handed over along with satisfaction note to the AO of the assessee. Accordingly, the AO of the assessee also recorded his satisfaction on 26.09.2018. The case of the assessee was centralized

Vaaan Infra Private Limited, Haryana vs. Deputy Commissioner of Income Tax, Central Circle, New Delhi

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 1524/Del/2025 : Asstt. Year: 2019-20 Ita No. 1525/Del/2025 : Asstt. Year: 2020-21 Vaaan Infra Pvt. Ltd., Vs Dcit, Villa-8, Block-Ii, Eros Garden, Central Circle-30, Charmwood Village, Surajkund New Delhi-110055 Road, Faridabad-121009 (Appellant) (Respondent) Pan No. Aadcv5910G Assessee By : Sh. Shiv Kumar Lath, Ca, Sh. Harish Kumar Choudhary, Ca & Sh. Mohit Choudhary, Ca Revenue By : Ms. Amish S. Gupt, Cit-Dr Date Of Hearing: 28.01.2026 Date Of Pronouncement: 28.01.2026 Order Per Satbeer Singh Godara: These Assessee’S Twin Appeals For Assessment Years 2019- 20 & 2020-21 Arise Against The Cit(A)-30, New Delhi’S Din & Order Nos. Itba/Apl/M/250/2024-25/1072166771(1) & 1072172353(1) Both Dated 15.01.2025, In Proceedings U/S 153C R.W.S. 143(3) Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

Vaaan Infra Pvt. Ltd. impugned section 153C proceedings/assessments itself as the assessee has filed a copy(ies) of the Assessing Officer’s corresponding satisfaction note before us which nowhere indicate that the seized material has been held as having any bearing on determination of it’s income. 4. Faced with ... this situation, learned CIT-DR vehemently argues that the impugned satisfaction note has rightly been recorded strictly in tune with section 153C of the Act wherein it is nowhere mandatory to incorporate the clinching statutory expression “bearing” therein. We are afraid that the Revenue’s forgoing vehement contentions hardly deserves

Vaaan Infra Private Limited, Faridabad vs. Deputy Commissioner of Income Tax, Jhandewalan Extension

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 1524/Del/2025 : Asstt. Year: 2019-20 Ita No. 1525/Del/2025 : Asstt. Year: 2020-21 Vaaan Infra Pvt. Ltd., Vs Dcit, Villa-8, Block-Ii, Eros Garden, Central Circle-30, Charmwood Village, Surajkund New Delhi-110055 Road, Faridabad-121009 (Appellant) (Respondent) Pan No. Aadcv5910G Assessee By : Sh. Shiv Kumar Lath, Ca, Sh. Harish Kumar Choudhary, Ca & Sh. Mohit Choudhary, Ca Revenue By : Ms. Amish S. Gupt, Cit-Dr Date Of Hearing: 28.01.2026 Date Of Pronouncement: 28.01.2026 Order Per Satbeer Singh Godara: These Assessee’S Twin Appeals For Assessment Years 2019- 20 & 2020-21 Arise Against The Cit(A)-30, New Delhi’S Din & Order Nos. Itba/Apl/M/250/2024-25/1072166771(1) & 1072172353(1) Both Dated 15.01.2025, In Proceedings U/S 153C R.W.S. 143(3) Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

Vaaan Infra Pvt. Ltd. impugned section 153C proceedings/assessments itself as the assessee has filed a copy(ies) of the Assessing Officer’s corresponding satisfaction note before us which nowhere indicate that the seized material has been held as having any bearing on determination of it’s income. 4. Faced with ... this situation, learned CIT-DR vehemently argues that the impugned satisfaction note has rightly been recorded strictly in tune with section 153C of the Act wherein it is nowhere mandatory to incorporate the clinching statutory expression “bearing” therein. We are afraid that the Revenue’s forgoing vehement contentions hardly deserves

Deputy Commissioner of Income Tax, Central Circle 25, New Delhi, Delhi vs. Shri Balaji Metal Tech Pvt Ltd, Haryana

In the result, the appeal of the revenue is allowed for statistical purpose

Bench: Shri C.N. Prasad & Shri Brajesh Kumar Singhassessment Year 2013-14 Commissioner Of Income Vs. Shri Balaji Metal Tech Pvt. Ltd. Tax,Centralcircle-25, New Haryana 20/21B, 2Nd Floor, Fruit Garden Delhi Nit Faridabad, Haryana Faridabad Pan No. Aaqcs0136E Appellant Respondent Appellant Sh. Mahesh Kumar, Cit Dr Respondent Sh. Madhur Aggarwal, Advocate

153C of the Act for AY 2013-2014, which proceedings are beyond the period of 6 years from the date of recording of satisfaction note by AO of the assessee le. 26.9.2019 and thus notice issued w/s 153C of the Act is without jurisdiction. "Additional Ground No. 2 That ... supra) and Hon’ble Supreme Court in the case of CIT Vs. Jasjit Singh (supra) has to be verified with the relevant satisfaction notes recorded by the Assessing officers as none of the SAT notes recorded are placed before us. We further observed that this ground was raised before

ACIT Cir-19(1), New Delhi vs. Shipra Bansal, New Delhi

In the result, appeal of the revenue is dismissed

Bench: SHRI ANUBHAV SHARMA, JUDICAL MEMBER, SHRI MANISH AGARWAL (Accountant Member)

proceedings u/s 153C of the act were initiated in the case of assessee after issue of notice u/s 153C on 29.03.2019 after recording the satisfaction note by the AO of the assessee on 18.02.2019. In compliance return of income was e-filed on 18.04.2019 declaring total income ... material available on record in the light of the applicable law. Through the additional ground, it has been argued by the appellant that the satisfaction note for issue of notice u/s 153C was recorded by the AO on 27.03.2019 (in F.Y. 2018-19 relevant

Manju Goyal, Delhi vs. Pr, CIT Central -3, Delhi

Appeal is allowed

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 3460/Del/2025 : Asstt. Year: 2016-17 Manju Goyal, Vs Pr. Cit (Central)-3, B-1/48, Phse-1, Ashok Vihar, New Delhi-110055 New Delhi-110052 (Appellant) (Respondent) Pan No. Aahpg9972E Assessee By : Ms. Rano Jain, Adv., Sh. Pranshu Singhal, Ca & Ms. Mansi Jain, Adv. Revenue By : Ms. Ankush Kalra, Sr. Dr Date Of Hearing: 27.01.2026 Date Of Pronouncement: 27.01.2026 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2016-17 Arises Against The Pcit(Central)-3, Delhi’S Din & Order No. Itba/Rev/F/Rev5/2024–25/1075213378(1) Dated 28.03.2025, In Proceedings U/S 263 Of The Income Tax Act, 1961 (In Short “The Act”).

search in light of PCIT vs. Abhisar Buildwell Pvt. Ltd. (2023) 454 ITR 212 (SC). We further find that even the relevant section 153C satisfaction note recorded on 21.06.2022 in the assessee’s case nowhere suggests that any such incriminating material was found which 3 Manju Goyal could be held ... have belonged, pertained or related to the assessee. This clinching satisfaction note compiled at page 18 of the paper book only suggests that the corresponding material was found/seized for financial years 2012-13 and 2013-14 than that involved herein i.e. assessment year 2016- 17. We accordingly

Geetanjali Bhayana, Delhi vs. DCIT Central Circle-32 Delhi, New Delhi

In the result, appeals of the assessee for AY 2019-20 and AY

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

seized contained some entries related to the assessee. Subsequently, satisfactions were recorded by AO of the searched person and the documents alongwith the satisfaction note was handed over to the AO of the assessee. Thereafter the AO of the assessee recorded his satisfaction note on 03.12.2021 and initiated the proceedings ... facts and circumstances of the present case, the impugned assessment proceedings u/s. 153C of the Act is void ab initio as separate satisfaction notes u/s.153C of the Act have not been prepared for each of the assessment years 2014-2015 to 2020-2021 which itself would render the impugned proceedings

Geetanjali Bhayana, Delhi vs. DCIT Central Circle-32 Delhi, New Delhi

In the result, appeals of the assessee for AY 2019-20 and AY

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

seized contained some entries related to the assessee. Subsequently, satisfactions were recorded by AO of the searched person and the documents alongwith the satisfaction note was handed over to the AO of the assessee. Thereafter the AO of the assessee recorded his satisfaction note on 03.12.2021 and initiated the proceedings ... facts and circumstances of the present case, the impugned assessment proceedings u/s. 153C of the Act is void ab initio as separate satisfaction notes u/s.153C of the Act have not been prepared for each of the assessment years 2014-2015 to 2020-2021 which itself would render the impugned proceedings

Geetanjali Bhayana, Delhi vs. DCIT Central Circle-32 Delhi, New Delhi

In the result, appeals of the assessee for AY 2019-20 and AY

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

seized contained some entries related to the assessee. Subsequently, satisfactions were recorded by AO of the searched person and the documents alongwith the satisfaction note was handed over to the AO of the assessee. Thereafter the AO of the assessee recorded his satisfaction note on 03.12.2021 and initiated the proceedings ... facts and circumstances of the present case, the impugned assessment proceedings u/s. 153C of the Act is void ab initio as separate satisfaction notes u/s.153C of the Act have not been prepared for each of the assessment years 2014-2015 to 2020-2021 which itself would render the impugned proceedings

Ritesh Kumar Gupta, New Delhi vs. ACIT, Central Circle-5, New Delhi

In the result, all the appeals of filed by the assessee are dismissed

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year 2011-12 Assessment Year 2012-13 Assessment Year 2013-14 Assessment Year 2014-15 Assessment Year 2016-17 Assessment Year 2017-18 Ritesh Kumar Gupta, Vs. Assistant Commissioner Of C-195, Opp. Mother Dairy Income Tax, Central Circle Booth, Nirmal Vihar, 5, New Delhi Vikas Marg, Delhi-110092 Pan No. Actpg0839J (Appellant) (Respondent)

Being aggrieved, the appellant/assessee preferred present appeals in ITA No. 688/Del/2020 is on following grounds: “1.Initiating proceedings u/s 153A of the Act without providing satisfaction note to the assessee; 2. Not considering the retraction of statement recorded under intimidation and pressure