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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

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 132(4)Section 153CSection 250Section 69Section 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 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

ITA 4779/DEL/2025[2024-25]Status: DisposedITAT Delhi11 Mar 2026AY 2024-25

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Revenue byFor Respondent: Shri Gaurav Jain, Adv
Section 12ASection 132Section 143(3)Section 2(15)

Learned PCIT in assuming jurisdiction based on reference made by the Learned Assessing Officer who had made such reference without recording any satisfaction note as prescribed under the second proviso to section 143(3) r.w.s.12AB(4)(b) of the Act. The 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

East Delhi Leasing P.Ltd, New Delhi vs. ITO, Ward-8(1), New Delhi

In the result, appeal filed by the assessee is allowed

ITA 7917/DEL/2019[2010-11]Status: DisposedITAT Delhi11 Mar 2026AY 2010-11

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 142(1)Section 147Section 148

report which is relied upon. 4.13 Specific objections were raised before the AO pointing out the invalidity of the satisfaction note recorded by him for the purpose of 14 ITA No. 7917/Del/2019 initiating reassessment proceedings through a notice u/s 148 of the Act in the subject case. The objections raised ... mind and not to have been led by the belief and opinion of any other authority. In this case the perusal of the satisfaction note would reveal that the AO launched the reassessment proceedings merely on the basis of the opinion of the Investigation Wing even though they

Pramod Subbiahnapalya Venkatpathi, Bangalore vs. DCIT, Central Circle-2(1), Bangalore

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

ITA 680/BANG/2025[2020-21]Status: DisposedITAT Bangalore10 Mar 2026AY 2020-21

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Vinay Simha, CAFor Respondent: Shri Subramanian, JCIT-DR
Section 132Section 142(1)Section 153CSection 69

assessee had raised a legal plea that, whether the AO can issue a notice u/s. 153C of the Act based on the common satisfaction note recorded for the A.Ys. 2015-16 to 2020-21. Another ground raised by the assessee is that whether the assessing officer is correct ... furnishing the copy of the satisfaction note based on which notices u/s. 153C were issued for the A.Ys. 2015-16 to 2020-21. 4. All the appeals are filed by the single assessee and the legal grounds are common to all the appeals except the grounds on merits and therefore

Pramod Subbiahnapalya Venkatpathi, Bangalore vs. DCIT, Central Circle-2(1), Bangalore

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

ITA 679/BANG/2025[2019-20]Status: DisposedITAT Bangalore10 Mar 2026AY 2019-20

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Vinay Simha, CAFor Respondent: Shri Subramanian, JCIT-DR
Section 132Section 142(1)Section 153CSection 69

assessee had raised a legal plea that, whether the AO can issue a notice u/s. 153C of the Act based on the common satisfaction note recorded for the A.Ys. 2015-16 to 2020-21. Another ground raised by the assessee is that whether the assessing officer is correct ... furnishing the copy of the satisfaction note based on which notices u/s. 153C were issued for the A.Ys. 2015-16 to 2020-21. 4. All the appeals are filed by the single assessee and the legal grounds are common to all the appeals except the grounds on merits and therefore

Pramod Subbiahnapalya Venkatpathi, Bengaluru vs. DCIT, Central Circle-2(1), Bangalore

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

ITA 678/BANG/2025[2018-19]Status: DisposedITAT Bangalore10 Mar 2026AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Vinay Simha, CAFor Respondent: Shri Subramanian, JCIT-DR
Section 132Section 142(1)Section 153CSection 69

assessee had raised a legal plea that, whether the AO can issue a notice u/s. 153C of the Act based on the common satisfaction note recorded for the A.Ys. 2015-16 to 2020-21. Another ground raised by the assessee is that whether the assessing officer is correct ... furnishing the copy of the satisfaction note based on which notices u/s. 153C were issued for the A.Ys. 2015-16 to 2020-21. 4. All the appeals are filed by the single assessee and the legal grounds are common to all the appeals except the grounds on merits and therefore

Pramod Subbiahnapalya Venkatathi, Bangalore vs. DCIT, Central Circle -2(1), Bangalore

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

ITA 677/BANG/2025[2017-18]Status: DisposedITAT Bangalore10 Mar 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Vinay Simha, CAFor Respondent: Shri Subramanian, JCIT-DR
Section 132Section 142(1)Section 153CSection 69

assessee had raised a legal plea that, whether the AO can issue a notice u/s. 153C of the Act based on the common satisfaction note recorded for the A.Ys. 2015-16 to 2020-21. Another ground raised by the assessee is that whether the assessing officer is correct ... furnishing the copy of the satisfaction note based on which notices u/s. 153C were issued for the A.Ys. 2015-16 to 2020-21. 4. All the appeals are filed by the single assessee and the legal grounds are common to all the appeals except the grounds on merits and therefore

Pramod Subbiahnapalya Venkatathi, Bengaluru vs. DCIT, Central Circle-2(1), Bangalore

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

ITA 676/BANG/2025[2016-17]Status: DisposedITAT Bangalore10 Mar 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Vinay Simha, CAFor Respondent: Shri Subramanian, JCIT-DR
Section 132Section 142(1)Section 153CSection 69

assessee had raised a legal plea that, whether the AO can issue a notice u/s. 153C of the Act based on the common satisfaction note recorded for the A.Ys. 2015-16 to 2020-21. Another ground raised by the assessee is that whether the assessing officer is correct ... furnishing the copy of the satisfaction note based on which notices u/s. 153C were issued for the A.Ys. 2015-16 to 2020-21. 4. All the appeals are filed by the single assessee and the legal grounds are common to all the appeals except the grounds on merits and therefore

Pramod Subbiahnapalya Venkatpathi, Bengaluru vs. DCIT, Central Circle-2(1), Bangalore

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

ITA 675/BANG/2025[2015-16]Status: DisposedITAT Bangalore10 Mar 2026AY 2015-16

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Vinay Simha, CAFor Respondent: Shri Subramanian, JCIT-DR
Section 132Section 142(1)Section 153CSection 69

assessee had raised a legal plea that, whether the AO can issue a notice u/s. 153C of the Act based on the common satisfaction note recorded for the A.Ys. 2015-16 to 2020-21. Another ground raised by the assessee is that whether the assessing officer is correct ... furnishing the copy of the satisfaction note based on which notices u/s. 153C were issued for the A.Ys. 2015-16 to 2020-21. 4. All the appeals are filed by the single assessee and the legal grounds are common to all the appeals except the grounds on merits and therefore

Jsp Projects (P) Ltd, Delhi vs. DCIT Central Circle - 13, Delhi

In the result appeal of the assessee in ITA number 3646/Del/2025 and

ITA 3647/DEL/2025[2021-22]Status: DisposedITAT Delhi09 Mar 2026AY 2021-22

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

Section 127(2)Section 153ASection 153CSection 63Section 65B

represented by an asset, the initiation of proceedings is bad in law. Page 2 of 26 ITA Nos.3643 to 3647/Del/2025 Non-supply of satisfaction note prepared by AO of searched person 3. That in the facts and circumstances of the case, the Ld. CIT(A) erred in law in sustaining ... completing the assessment proceedings u/s 153C of the Act for the assessment year under consideration without bringing on record the copy of the satisfaction note recorded by the Ld AO having jurisdiction over the searched person. That, the assessment order passed u/s 153C without satisfying the mandatory jurisdiction condition

Jsp Projects (P) Ltd, Delhi vs. DCIT Central Circle - 13, Delhi

In the result appeal of the assessee in ITA number 3646/Del/2025 and

ITA 3646/DEL/2025[2020-21]Status: DisposedITAT Delhi09 Mar 2026AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

Section 127(2)Section 153ASection 153CSection 63Section 65B

represented by an asset, the initiation of proceedings is bad in law. Page 2 of 26 ITA Nos.3643 to 3647/Del/2025 Non-supply of satisfaction note prepared by AO of searched person 3. That in the facts and circumstances of the case, the Ld. CIT(A) erred in law in sustaining ... completing the assessment proceedings u/s 153C of the Act for the assessment year under consideration without bringing on record the copy of the satisfaction note recorded by the Ld AO having jurisdiction over the searched person. That, the assessment order passed u/s 153C without satisfying the mandatory jurisdiction condition

Jsp Projects (P) Ltd, Delhi vs. DCIT Central Circle -13, Delhi

In the result appeal of the assessee in ITA number 3646/Del/2025 and

ITA 3645/DEL/2025[2019-20]Status: DisposedITAT Delhi09 Mar 2026AY 2019-20

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

Section 127(2)Section 153ASection 153CSection 63Section 65B

represented by an asset, the initiation of proceedings is bad in law. Page 2 of 26 ITA Nos.3643 to 3647/Del/2025 Non-supply of satisfaction note prepared by AO of searched person 3. That in the facts and circumstances of the case, the Ld. CIT(A) erred in law in sustaining ... completing the assessment proceedings u/s 153C of the Act for the assessment year under consideration without bringing on record the copy of the satisfaction note recorded by the Ld AO having jurisdiction over the searched person. That, the assessment order passed u/s 153C without satisfying the mandatory jurisdiction condition

Jsp Projects (P) Ltd, Delhi vs. DCIT Central Circle - 13, Delhi

In the result appeal of the assessee in ITA number 3646/Del/2025 and

ITA 3644/DEL/2025[2016-17]Status: DisposedITAT Delhi09 Mar 2026AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

Section 127(2)Section 153ASection 153CSection 63Section 65B

represented by an asset, the initiation of proceedings is bad in law. Page 2 of 26 ITA Nos.3643 to 3647/Del/2025 Non-supply of satisfaction note prepared by AO of searched person 3. That in the facts and circumstances of the case, the Ld. CIT(A) erred in law in sustaining ... completing the assessment proceedings u/s 153C of the Act for the assessment year under consideration without bringing on record the copy of the satisfaction note recorded by the Ld AO having jurisdiction over the searched person. That, the assessment order passed u/s 153C without satisfying the mandatory jurisdiction condition

Jsp Projects (P) Ltd, Delhi vs. DCIT Central Circle - 13, Delhi

In the result appeal of the assessee in ITA number 3646/Del/2025 and

ITA 3643/DEL/2025[2015-16]Status: DisposedITAT Delhi09 Mar 2026AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

Section 127(2)Section 153ASection 153CSection 63Section 65B

represented by an asset, the initiation of proceedings is bad in law. Page 2 of 26 ITA Nos.3643 to 3647/Del/2025 Non-supply of satisfaction note prepared by AO of searched person 3. That in the facts and circumstances of the case, the Ld. CIT(A) erred in law in sustaining ... completing the assessment proceedings u/s 153C of the Act for the assessment year under consideration without bringing on record the copy of the satisfaction note recorded by the Ld AO having jurisdiction over the searched person. That, the assessment order passed u/s 153C without satisfying the mandatory jurisdiction condition

Abdullatif Ibrahim Badarpura, Mumbai vs. DCIT Central Circle 4(2), Mumbai

ITA 8407/MUM/2025[2018-2019]Status: DisposedITAT Mumbai27 Feb 2026AY 2018-2019

Bench: Shri Narender Kumar Choudhry & Shri Jagadish

Section 132Section 153Section 250

along with the relevant details and documents. Further, in the 7 ITA No..8406/Mum/2025&Ors. Ashok Hanjaji Mali & Abdullatif Ibrahim Badarpura & Amararam Mali satisfaction note, all the details were mentioned and communicated to the Assessee, which also contains the Excel sheets, detailing the shop number, area, level, total amount ... submitted that the assessee was provided with the show-cause notice dated 17.01.2024 along with the relevant details and documents. Further, in the satisfaction note, all the details are mentioned and communicated to the assessee, which also contains the Excel sheets, detailing the shop number, area, level, total amount