← All Phrases

“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

Quadra Infratel Synergies Pvt Ltd, Delhi vs. ACIT, Central Circle 4, Delhi, Jhandewalan

In the result, the appeal of the assessee is allowed as indicated above

ITA 3963/DEL/2024[2014-15]Status: DisposedITAT Delhi12 Dec 2025AY 2014-15

Bench: Shri C.N. Prasad & Shri M. Balaganesh[Assessment Year: 2014-15] Quadra Infratel Synergies Vs. Acit Pvt. Ltd. B-6/1, Sector-05 Central Circle – 4 Rohini, Delhi Delhi Pan No. Aaecp2894G Appellant Respondent Assessee By Sh. Saksham Singhal, Advocate Ms. Somay Jain, Ca Revenue By Ms. Nimisha Singh, Cit Dr Date Of Hearing 18.09.2025 Date Of Pronouncement 12.12.2025 Order Per C.N. Prasad, Jm, This Appeal Filed By The Assessee Is Preferred Against The Order Of The Commissioner Of Income Tax (Appeals), Delhi - 110023 [Herein After Referred As “Cit(A)”] Dated 29.06.2024 For A.Y. 2014-15. 2. The Assessee Has Raised Following Grounds On Validity Of Assessment Proceedings :- “1. That On The Facts & Circumstances Of The Case & In Law, The Commissioner Of Income Tax (Appeals) ['Cit(A)'] Erred In Not Completely Allowing The Appeal Filed By The Appellant Against The Order Dated 29.03.2023 Passed By The Assessing Officer Under Section 1530 R.W.S 143(3) Of The Income Tax Act, 1961 ('The Act").

Section 143(3)Section 153Section 153ASection 153CSection 153DSection 28Section 69A

facts and in law in passing the assessment order without affording reasonable opportunity of being heard and without providing the requisite documents (such as satisfaction note recorded by assessing officer of the search person alongwith Proforma, alleged loose sheets, etc.) to the appellant and consequently, the assessment order is illegal ... searched person to AO of non- searched person i.e. Assessee is on 26.10.2021. Thereafter, the AO of the assessee recorded satisfaction note on 24.01.2022. The Ld. Counsel for the assessee submitted that the block period for making assessment u/s.153C was considered by the AO taking the year of search