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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

Shweta Puneet Kulthia, Delhi vs. DCIT, Central Circle-14, Delhi

In the result, the appeal filed by the assessee is allowed

ITA 1055/DEL/2025[2014-15]Status: DisposedITAT Delhi27 Nov 2025AY 2014-15

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 143(2)Section 153ASection 153CSection 153DSection 250Section 69A

quashed and CIT(A) erred in not holding so. 3. On the facts and circumstances of the case and in law, the satisfaction note (s) recorded u/s 153C of the Act are bad-in-law and without jurisdiction and, accordingly, the assessment proceedings initiated on the foundation of such satisfaction

Shweta Puneet Kulthia, Delhi vs. DCIT, Central Circle-14, Delhi

In the result, the appeal filed by the assessee is allowed

ITA 1054/DEL/2025[2013-14]Status: DisposedITAT Delhi27 Nov 2025AY 2013-14

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 143(2)Section 153ASection 153CSection 153DSection 250Section 69A

quashed and CIT(A) erred in not holding so. 3. On the facts and circumstances of the case and in law, the satisfaction note (s) recorded u/s 153C of the Act are bad-in-law and without jurisdiction and, accordingly, the assessment proceedings initiated on the foundation of such satisfaction

Shokeen Construction Co., Delhi vs. DCIT, Central Circle-30 Delhi, Delhi

In the result, appeal of the assessee is allowed

ITA 5973/DEL/2024[2020-21]Status: HeardITAT Delhi27 Nov 2025AY 2020-21

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 153ASection 153CSection 153DSection 250Section 37

books under tally software were found and seized from the office premises of Shri Sanjay Jain. On the basis of information available, a satisfaction note was prepared by the AO of person searched i.e. DCIT, Central Circle-30, New Delhi proposing for initiation of proceedings u/s 153C ... quashed and CIT(A) erred in not holding so. 3. On the facts and circumstances of the case and in law, the satisfaction note(s) recorded u/s 153C of the Act are bad-in-law and without jurisdiction and, accordingly, the assessment proceedings initiated on the foundation of such satisfaction

Shokeen Construction Co., Delhi vs. DCIT, Central Circle-30, Delhi

In the result, appeal of the assessee is allowed

ITA 5972/DEL/2024[2019-20]Status: HeardITAT Delhi27 Nov 2025AY 2019-20

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 153ASection 153CSection 153DSection 250Section 37

books under tally software were found and seized from the office premises of Shri Sanjay Jain. On the basis of information available, a satisfaction note was prepared by the AO of person searched i.e. DCIT, Central Circle-30, New Delhi proposing for initiation of proceedings u/s 153C ... quashed and CIT(A) erred in not holding so. 3. On the facts and circumstances of the case and in law, the satisfaction note(s) recorded u/s 153C of the Act are bad-in-law and without jurisdiction and, accordingly, the assessment proceedings initiated on the foundation of such satisfaction

Shokeen Construction Co., Delhi vs. DCIT Central Circle-30, Delhi

In the result, appeal of the assessee is allowed

ITA 5971/DEL/2024[2018-19]Status: HeardITAT Delhi27 Nov 2025AY 2018-19

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 153ASection 153CSection 153DSection 250Section 37

books under tally software were found and seized from the office premises of Shri Sanjay Jain. On the basis of information available, a satisfaction note was prepared by the AO of person searched i.e. DCIT, Central Circle-30, New Delhi proposing for initiation of proceedings u/s 153C ... quashed and CIT(A) erred in not holding so. 3. On the facts and circumstances of the case and in law, the satisfaction note(s) recorded u/s 153C of the Act are bad-in-law and without jurisdiction and, accordingly, the assessment proceedings initiated on the foundation of such satisfaction

Ravi Rambabu, Hyderabad vs. ACIT., Central Circle 2(3), Hyderabad

ITA 651/HYD/2025[2020-21]Status: DisposedITAT Hyderabad26 Nov 2025AY 2020-21

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No. 651/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2020-21) Ravi Rambabu, Vs. Assistant Commissioner Hyderabad. Of Income Tax, Circle-2(3), Pan: Abspr3702P Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 17/11/2025 घोषणा की तारीख/Date Of 26/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Rectification Order Dated 28.03.2025 Passed By The Cit (Appeals) Under Section 154 Of The Income-Tax Act, 1961 (For Short, “Act"), Dated 28.03.2025, Which In Turn Arises From The Order Passed By The Cit(A) Disposing Of The Assessee’S Appeal, Vide His Order Dated 29.01.2025. The Assessee Has Assailed The Impugned Order Passed By The Cit(A)

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 115BSection 139(1)Section 143(3)Section 153ASection 153BSection 153CSection 154Section 68Section 69Section 69A

meantime, the seized material was handed over by the Investigation Wing to the AO on 01.09.2020. Thereafter, in response to the “satisfaction note” recorded under Section 153C(2)(b) of the Act, the AO issued notice under Section 153C of the Act on 30.09.2021. In compliance, the assessee filed ... observed by him that the seized material was handed over by the Investigation Wing to the AO on 01.09.2020. Further, the “satisfaction note” under Section 153C(2)(b) was recorded, and the notice was issued by the AO on 8 Ravi Rambabu vs. ACIT 30.09.2021. Thereafter, the assessment order

Balatripura Sundari Donepudi, Hyderabad vs. DCIT., Central Circle - 1(4), Hyderabad

ITA 556/HYD/2025[2016-17]Status: DisposedITAT Hyderabad26 Nov 2025AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No. 556/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Balatripura Sundari Vs. Deputy Commissioner Donepudi, Of Income Tax, Hyderabad. Central Circle-1(4), Pan: Afhpd2082B Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By: Shri Gurpreet Singh, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 16/10/2025 घोषणा की तारीख/Date Of 26/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M:

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Shri Gurpreet Singh, Sr. AR
Section 132Section 143(3)Section 153CSection 250Section 69

recorded satisfaction that the papers relate to the assessee. Since the AO was common to both the searched person and the assessee, and the satisfaction note clearly refers to the assessee, therefore, we hold that the proceedings under section 153C were validly initiated. 5 Balatripura Sundari Donepudi vs. DCIT

M/S. Bannariamman Educational Trust, Coimbatore vs. PCIT, CC-3(2), Chennai

In the result, appeals filed by the assessee are allowed

ITA 1379/CHNY/2025[2016-17]Status: DisposedITAT Chennai26 Nov 2025AY 2016-17

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

Section 11Section 143(3)Section 153CSection 263

assessee to Chettinad Builders in connection with buildings constructed by Chettinad Builders for the assessee, the AO is noted to have recorded his ‘Satisfaction Note’ u/s.153C and notice was issued on 29.01.2022; and then the assessment from AY 2015-16 to 2020-21 was reopened for assessment u/s.153C

Bannariamman Educational Trust, Coimbatore vs. PCIT, Central Circle-3(2), Chennai

In the result, appeals filed by the assessee are allowed

ITA 1378/CHNY/2025[2015-16]Status: DisposedITAT Chennai26 Nov 2025AY 2015-16

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

Section 11Section 143(3)Section 153CSection 263

assessee to Chettinad Builders in connection with buildings constructed by Chettinad Builders for the assessee, the AO is noted to have recorded his ‘Satisfaction Note’ u/s.153C and notice was issued on 29.01.2022; and then the assessment from AY 2015-16 to 2020-21 was reopened for assessment u/s.153C

Revelation Unique Retail and Marketing Private Limited, Delhi vs. Assistant Commissioner of Income Tax, Central Circle-3, Delhi

In the result, the appeal filed by the assessee is allowed

ITA 466/DEL/2025[2019-20]Status: DisposedITAT Delhi26 Nov 2025AY 2019-20

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2019-20 Revelation Unique Retail & Vs. Assistant Commissioner Of Income Marketing Private Ltd., Tax, Central Circle-3, 5A/3A, Ansari Road, Daryaganj, Delhi New Delhi Pin: 1100 02 Pan :Aaicr9933L (Appellant) (Respondent)

Section 115BSection 127Section 132Section 142(1)Section 153CSection 234BSection 234CSection 250Section 272A(1)(d)Section 274

grossly erred in not rendering the notice issued under Section 153C and consequent assessment bad in law as the satisfaction note recorded by the Ld. AO is invalid, bad in law and void ab initio; 3. That on the facts and circumstances of the case no addition can be made ... appellant/assessee submitted that Ld. CIT(A) grossly erred in not rendering notice under Section 153C and consequent assessment bad in law as the satisfaction note recorded is bad in law, and void-ab-initio on following counts: i. The said satisfaction note does not provide the details of the documents

Anshul Bansal, Delhi vs. Assistant Commissioner of Income Tax Central Circle 3, Delhi

In the result, the appeal filed by the assessee is allowed

ITA 465/DEL/2025[2019-20]Status: DisposedITAT Delhi26 Nov 2025AY 2019-20

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2019-20 Ansul Bansal, Vs. Assistant Commissioner Of Income 5A/3A, Ansari Road, Daryaganj, Tax, Circle-3, New Delhi Delhi Pin: 1100 02 Pan :Auqpb8298M (Appellant) (Respondent)

Section 127Section 132Section 142(1)Section 143(2)Section 153CSection 250Section 272A(1)(d)Section 274Section 53CSection 69A

response to the notice. Hence, penalty order under Section 272A(1)(d) of the Act was passed on 03.12.2022. The copy of the satisfaction note was provided to the assessee on 13.01.2023. As per the submissions made by the assessee, during the year under consideration the assessee has derived income ... grossly erred in not rendering the notice issued under section 153C and consequent assessment bad in law as the satisfaction note recorded by the Ld. AO is invalid, bad in law and void ab initio 3. That on the facts and circumstances of the case

Shri Narendra Charitable Trust, Delhi vs. Pr. Commissioner of Income Tax (Central) - 3, Delhi

In the result, the assessees’ appeals are allowed

ITA 253/DEL/2025[2014-15 and Further Year]Status: DisposedITAT Delhi26 Nov 2025
Section 120Section 127Section 12ASection 143Section 3

Income Tax (Exemption) as per section 127 r.w.s section 120 of Income Tax Act, Page 4 of 27 1961 and without sharing any satisfaction note to the assessee in term of sub section 3 of the section 143 of the Act. 6. That your appellant trust craves leave

Shakuntalam Educational Society East Delhi, New Delhi vs. Pr. Commissioner of Income Tax (Central)- 3, Delhi

In the result, the assessees’ appeals are allowed

ITA 252/DEL/2025[2013-14 and Further Years]Status: DisposedITAT Delhi26 Nov 2025
Section 120Section 127Section 12ASection 143Section 3

Income Tax (Exemption) as per section 127 r.w.s section 120 of Income Tax Act, Page 4 of 27 1961 and without sharing any satisfaction note to the assessee in term of sub section 3 of the section 143 of the Act. 6. That your appellant trust craves leave

Adarsh Shiv Shakti Shiksha Samiti, Delhi vs. Pr. Commissioner of Income Tax (Central) - 3, Delhi

In the result, the assessees’ appeals are allowed

ITA 218/DEL/2025[2013-14 and further years]Status: DisposedITAT Delhi26 Nov 2025
Section 120Section 127Section 12ASection 143Section 3

Income Tax (Exemption) as per section 127 r.w.s section 120 of Income Tax Act, Page 4 of 27 1961 and without sharing any satisfaction note to the assessee in term of sub section 3 of the section 143 of the Act. 6. That your appellant trust craves leave

Presidium Educational & Charitable Trust, Delhi vs. Pr. Commissioner of Income Tax (Central) - 3, Delhi

In the result, the assessees’ appeals are allowed

ITA 216/DEL/2025[2012-13 and further year]Status: DisposedITAT Delhi26 Nov 2025
Section 120Section 127Section 12ASection 143Section 3

Income Tax (Exemption) as per section 127 r.w.s section 120 of Income Tax Act, Page 4 of 27 1961 and without sharing any satisfaction note to the assessee in term of sub section 3 of the section 143 of the Act. 6. That your appellant trust craves leave

Divine Educational and Charitable Trust, Delhi vs. Pr. Commissioner of Income Tax (Central) - 3, Delhi

In the result, the assessees’ appeals are allowed

ITA 215/DEL/2025[2014-15 and further years]Status: DisposedITAT Delhi26 Nov 2025
Section 120Section 127Section 12ASection 143Section 3

Income Tax (Exemption) as per section 127 r.w.s section 120 of Income Tax Act, Page 4 of 27 1961 and without sharing any satisfaction note to the assessee in term of sub section 3 of the section 143 of the Act. 6. That your appellant trust craves leave

Nathaneil Junior Education Society, Delhi vs. Pr. Commissioner of Income Tax (Central) - 3, Delhi

In the result, the assessees’ appeals are allowed

ITA 214/DEL/2025[2014-15 and Further Years]Status: DisposedITAT Delhi26 Nov 2025
Section 120Section 127Section 12ASection 143Section 3

Income Tax (Exemption) as per section 127 r.w.s section 120 of Income Tax Act, Page 4 of 27 1961 and without sharing any satisfaction note to the assessee in term of sub section 3 of the section 143 of the Act. 6. That your appellant trust craves leave

Deputy Commissioner of Income Tax, Delhi vs. Somani Worsted Limited, New Delhi

In the result, the appeal of the Revenue in quantum addition is dismissed

ITA 1558/DEL/2025[2011-12]Status: DisposedITAT Delhi26 Nov 2025AY 2011-12

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Raj Kumar Gupta, CAFor Respondent: Ms. Suman Malik, CIT DR
Section 132Section 144Section 153ASection 153CSection 271(1)(c)Section 60

asstt. year” as defined in Expln-1 below 4 Proviso to Sec.153A, consequently barred by limitation and without jurisdiction. Additional G.No.2 That consolidate/single satisfaction note by the AO of the assessee for asstt. years 2008-09 to 2018-19, since legally invalid and cannot be acted upon, hence ... impugned asstt. framed in pursuance to said illegal satisfaction note is without jurisdiction, illegal and liable to be quashed. Additional G.No.3 That under the facts and circumstances, A.Y. 2011-12 being unabated year, hence in the absence of any incriminating material found/seized during the course of search

Deputy Commissioner of Income Tax, Delhi vs. Somani Worsted Limited, Delhi

In the result, the appeal of the Revenue in quantum addition is dismissed

ITA 1557/DEL/2025[2011-12]Status: DisposedITAT Delhi26 Nov 2025AY 2011-12

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Raj Kumar Gupta, CAFor Respondent: Ms. Suman Malik, CIT DR
Section 132Section 144Section 153ASection 153CSection 271(1)(c)Section 60

asstt. year” as defined in Expln-1 below 4 Proviso to Sec.153A, consequently barred by limitation and without jurisdiction. Additional G.No.2 That consolidate/single satisfaction note by the AO of the assessee for asstt. years 2008-09 to 2018-19, since legally invalid and cannot be acted upon, hence ... impugned asstt. framed in pursuance to said illegal satisfaction note is without jurisdiction, illegal and liable to be quashed. Additional G.No.3 That under the facts and circumstances, A.Y. 2011-12 being unabated year, hence in the absence of any incriminating material found/seized during the course of search

Dy. Commissioner of Income Tax, Central Circle-17, Delhi vs. M/S Mani Capital Limited, Kanpur

In the result, the appeal of AY 2010-11 is allowed

ITA 3863/DEL/2025[2013-14]Status: DisposedITAT Delhi25 Nov 2025AY 2013-14

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 153Section 153ASection 153CSection 153C(1)Section 37

sent by the Ld. Assessing Officer (‘AO’) of searched person to the Ld. AO of the respondent assessee in June, 2022. Thereafter, the satisfaction note to initiate proceedings under section 153C of the Act was recorded in FY 2022-23 relevant to A.Y. 2023-24. The Ld. AR further submitted ... notice under section 153C of the Act from the end of the relevant previous year in which search conducted on the assessee (the satisfaction note to initiate proceedings under section 153C of the Act was recorded in FY 2022-23 relevant to A.Y. 2023-24) were as under