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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

Gdr Finance and Leasing P. Ltd, Delhi vs. Income Tax Officer, Delhi

In the result, the appeal of the assessee is allowed

ITA 802/DEL/2025[2018-19]Status: DisposedITAT Delhi23 Dec 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarassessment Year : 2018-19 M/S Gdr Finance & Leasing Vs. Assessment Unit, Pvt. Ltd., Income Tax Officer, 323, Agrawal Plaza, Nfac. Dda Community Centre, Shalimar Bagh, New Delhi – 110 088. Pan: Aaacg2363D (Appellant) (Respondent) Assessee By : Shri C.S. Aggarwal, Sr. Advocate; Shri Rupinder Aggarwal, Shri R.P. Mall, Shri Uma Shankar, Ms Suman Verma & Ms Vidushi Aggarwal, Advocates Revenue By : Shri Om Parkash, Sr. Dr Date Of Hearing : 29.10.2025 Date Of Pronouncement : 23.12.2025 Order Per Vimal Kumar, Jm:

For Appellant: Shri C.S. Aggarwal, Sr. AdvocateFor Respondent: Shri Om Parkash, Sr. DR
Section 133(6)Section 142Section 143(2)Section 147Section 148Section 148ASection 151ASection 250

paper book). On 21.03.2022, the assessee received a notice u/s 148A(b) of the Income Tax Act (Pg. 78-79 of PB) 5.1. In satisfaction note, it is alleged that credible information has been received from ld. DDIT (Inv.) Unit - 2(4) New Delhi that the appellant had taken accommodation ... should not be issued on the basis of information available for AY 2018-19 as per facts discussed above.” 7.1 The reasons in the satisfaction note referred to credible information received from ld.DDIT that the assessee had taken accommodation entry of Rs.47,65,476/- through M/s K.G. Finvest

Deputy Commissioner of Income Tax, Central Circle vs. Maruti Enterprise, Rajkot

ITA 228/RJT/2023[2019-20]Status: DisposedITAT Rajkot22 Dec 2025AY 2019-20

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhasr. It(Ss)A No Assessment Assessee Name Respondent Name No. Year 1. 12/Rjt/2024 2014-15 Deputy Commissioner Shri Chetan Dhirajlal Rokad Of Income-Tax, Central 1, Pearl Plaza, 150 Ft Ring Circle-1, Rajkot, Road, Near G.T. School “Amruta Estate” 2Nd Rajkot-360 001 Floor, M.G. Road, Rajkot-360 001 Pan.:Afkpr4637P 2. 13/Rjt/2024 2014-15 Deputy Commissioner Shri Nikhilbhai Jamnadas Of Income-Tax, Central Patel Circle-1, Rajkot, P-1, Decora Highland, “Amruta Estate” 2Nd Avadh Main Road, Opp. Floor, M.G. Road, Classic Party Plot Rajkot- Rajkot-360 001 360 005 Pan No.: Agipp 1294 K 3. 17/Rjt/2024 2013-14 Deputy Commissioner Shri Dhirajlal Ravji Rokad Of Income-Tax, Central 1, Pearl Plaza, 150 Ft Ring Circle-1, Rajkot, Road, Near G.T. School “Amruta Estate” 2Nd Rajkot-360 001 Floor, M.G. Road, Rajkot-360 001 Panno.:Abopr5408A 19 & 2017-18 & Deputy Commissioner Shri Rohitkumar Maganlal 4. 20/Rjt/2024 2018-19 Of Income-Tax, Central Sanepara Circle-1, Rajkot, Kangshiyani Road, Opp. “Amruta Estate” 2Nd Sundaram Vidhyalaya, Floor, M.G. Road, Dholra Chokdi, Kothariya, Rajkot-360 001 Rajkot-360 004 Panno.:Aaopp4848H 5. 59-60/Rjt/2023 2017-18 & Deputy Commissioner M/S Maruti Enterprise 2018-19 Of Income-Tax, Central Decora West Hills, Near Classic Party Plot, Opp. Circle-1, Rajkot, Kalawa Road, Rajkot-360 “Amruta Estate” 2Nd 005 Floor, M.G. Road, Rajkot-360 001 Panno.:Abdfm3140K 6. 228/Rjt/2023 2019-20 Deputy Commissioner M/S Maruti Enterprise Of Income-Tax, Central

Section 250

issued on 28.01.2021. Thereafter, two detailed show cause notices were issued on 07.04.2021. The assessee -firm was furnished copy of satisfaction note as and when requested. In the present case, there are two issues. One is unaccounted investment in order to possess land to the tune