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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

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

ITA 8406/MUM/2025[2017-2018]Status: DisposedITAT Mumbai27 Feb 2026AY 2017-2018

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

Ashok Hanjaji Mali, Mumbai vs. The Assistant Commissioner of Income Tax, Central Circle 4(2), Mumbai

ITA 7804/MUM/2025[2019-2020]Status: DisposedITAT Mumbai27 Feb 2026AY 2019-2020

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

Ashok Hanjaji Mali, Mumbai vs. The Assistant Commissioner of Income Tax Central Circle 4(2)Mumbai, Mumbai

ITA 7803/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

Jain Sanjaykumar Sohanraj HUF, Mumbai vs. DCIT Central Circle, Mumbai

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

ITA 7114/MUM/2025[2020-21]Status: DisposedITAT Mumbai27 Feb 2026AY 2020-21

Bench: Hon’Ble Shri Sandeep Gosain& Hon’Ble Shri Bijayananda Pruseth

Section 132(4)Section 153CSection 250Section 69

erred in confirming addition without referring to any incrementing document. Besides, he has not referred to any incriminating material in the satisfaction note issued to the Appellant. 3. On the facts and circumstances of the case in law, Ld. CIT(A) erred in confirming stand of A.O. for not sharing ... statements were used against the appellant 6. On the facts and circumstances of the case in law, Ld. CIT(A) erred in recording consolidated satisfaction note under section 153C of Income Tax Act 1961, for multiple assessment years, thereby vitiating the entire proceedings.” 7. On the facts and circumstances

Jain Sanjaykumar Sohanraj HUF, Mumbai vs. DCIT, Central Circle, Mumbai

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

ITA 7113/MUM/2025[2019-20]Status: DisposedITAT Mumbai27 Feb 2026AY 2019-20

Bench: Hon’Ble Shri Sandeep Gosain& Hon’Ble Shri Bijayananda Pruseth

Section 132(4)Section 153CSection 250Section 69

erred in confirming addition without referring to any incrementing document. Besides, he has not referred to any incriminating material in the satisfaction note issued to the Appellant. 3. On the facts and circumstances of the case in law, Ld. CIT(A) erred in confirming stand of A.O. for not sharing ... statements were used against the appellant 6. On the facts and circumstances of the case in law, Ld. CIT(A) erred in recording consolidated satisfaction note under section 153C of Income Tax Act 1961, for multiple assessment years, thereby vitiating the entire proceedings.” 7. On the facts and circumstances

Assistant Commissioner of Income Tax, Central Circle-2, Patna vs. Patna Iron Pvt. Ltd., Patna

In the result, the appeals of the assessee are allowed and appeal of the Revenue is dismissed

ITA 373/PAT/2025[2020-21]Status: DisposedITAT Patna26 Feb 2026AY 2020-21

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Appellant) (Respondent) Pan No. Aafcp2484B Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Respondent) (Appellant) Sushil Kumar Kanodia N-601, Profesor Colony, Acit, Central Circle-2 Chitragupta Nagar, Kanakrbagh, Vs. Patna, Bihar Patna-800020, Bihar (Appellant) (Respondent) Pan No. Agypk0702D Assessee By : Shri Manish Rastogi, Ar Revenue By : Md. A.H. Chowdhary, Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 26.02.2025

For Appellant: Shri Manish Rastogi, ARFor Respondent: Md. A.H. Chowdhary, DR
Section 132Section 143(2)Section 143(3)Section 153ASection 153C

decision of Bhawna Garg vs DCIT Central, reported in [2025] 180 taxmann.com 9 (Delhi - Trib.), wherein it has been held that when the satisfaction note was recorded in the next financial year of the search and seizure operation conducted in the case of the third party, the year of search ... would be the next assessment year in which the satisfaction note was recorded. Therefore the assessment year fell within the block period of six years and the assessment ought to have been completed under section 153C of the Act and the assessment completed under section

Patna Iron Pvt. Ltd., Patna vs. ACIT, Central Circle-2, Patna

In the result, the appeals of the assessee are allowed and appeal of

ITA 332/PAT/2025[2020-21]Status: DisposedITAT Patna26 Feb 2026AY 2020-21

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

For Appellant: Shri Manish Rastogi, ARFor Respondent: Md. A.H. Chowdhary, DR
Section 132Section 143(2)Section 143(3)Section 153ASection 153C

decision of Bhawna Garg vs DCIT Central, reported in [2025] 180 taxmann.com 9 (Delhi - Trib.), wherein it has been held that when the satisfaction note was recorded in the next financial year of the search and seizure operation conducted in the case of the third party, the year of search ... would be the next assessment year in which the satisfaction note was recorded. Therefore the assessment year fell within the block period of six years and the assessment ought to have been completed under section 153C of the Act and the assessment completed under section

Sushil Kumar Kanodia, Patna vs. ACIT, Central Circle-2, Patna

In the result, the appeals of the assessee are allowed and appeal of the Revenue is dismissed

ITA 237/PAT/2025[2017-18]Status: DisposedITAT Patna26 Feb 2026AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Appellant) (Respondent) Pan No. Aafcp2484B Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Respondent) (Appellant) Sushil Kumar Kanodia N-601, Profesor Colony, Acit, Central Circle-2 Chitragupta Nagar, Kanakrbagh, Vs. Patna, Bihar Patna-800020, Bihar (Appellant) (Respondent) Pan No. Agypk0702D Assessee By : Shri Manish Rastogi, Ar Revenue By : Md. A.H. Chowdhary, Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 26.02.2025

For Appellant: Shri Manish Rastogi, ARFor Respondent: Md. A.H. Chowdhary, DR
Section 132Section 143(2)Section 143(3)Section 153ASection 153C

decision of Bhawna Garg vs DCIT Central, reported in [2025] 180 taxmann.com 9 (Delhi - Trib.), wherein it has been held that when the satisfaction note was recorded in the next financial year of the search and seizure operation conducted in the case of the third party, the year of search ... would be the next assessment year in which the satisfaction note was recorded. Therefore the assessment year fell within the block period of six years and the assessment ought to have been completed under section 153C of the Act and the assessment completed under section

Jesaram Purohit, Mumbai vs. DCIT, Central Circle 4(2), Mumbai

ITA 8346/MUM/2025[2018-19]Status: DisposedITAT Mumbai26 Feb 2026AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

For Appellant: 1. On the facts and circumstances of the case in law, Ld
Section 132Section 132(4)Section 153CSection 69

erred in confirming addition without referring to any incrementing document. Besides, he has not referred to any incriminating material in the satisfaction note issued to the Appellant. 3. On the facts and circumstances of the case in law, Ld. N.A. CIT(A) erred in confirming stand

Jesaram Purohit, Mumbai vs. DCIT, Central Circle 4(2), Mumbai

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

ITA 8345/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Feb 2026AY 2019-20

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

For Appellant: 1. On the facts and circumstances of the case in law, L.d
Section 132Section 132(4)Section 153CSection 69

erred in confirming addition without referring to any incrementing document. Besides, he has not referred to any incriminating material in the satisfaction note issued to the Appellant. 3. On the facts and circumstances of the case in law, Ld. N.A. CIT(A) erred in confirming stand

Jesaram Purohit, Mumbai vs. DCIT, Central Circle 4(2), Mumbai

ITA 8344/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

For Appellant: 1. On the facts and circumstances of the case in law, L.d
Section 132(4)Section 153CSection 69

erred in confirming addition without referring to any incrementing document. Besides, he has not referred to any incriminating material in the satisfaction note issued to the Appellant. 3. On the facts and circumstances of the case in law, Ld. N.A. CIT(A) erred in confirming stand

Juararam Chogaji Purohit, Mumbai vs. DCIT Central Circle, Mumbai

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

ITA 8193/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Feb 2026AY 2019-20

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

For Appellant: 1. On the facts and circumstances of the case in law
Section 153CSection 69

erred in confirming addition without referring to any incrementing document. Besides, he has not referred to any incriminating material in the satisfaction note issued to the Appellant. 3. On the facts and circumstances of the case in law, Ld. CIT(A) erred in confirming stand of A.O. for not sharing ... facts and in the circumstances of the case, the N.A learned CIT(A) has erred in upholding the validity of a common satisfaction note recorded for multiple assessment years. The appellant submits that such a consolidated satisfaction is bad in law, since satisfaction under the relevant provisions must be recorded

Juararam Chogaji Purohit, Mumbai vs. DCIT Central Circle 4(2), Mumbai

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

ITA 8192/MUM/2025[2018-19]Status: DisposedITAT Mumbai26 Feb 2026AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

For Appellant: 1. On the facts and circumstances of the case in law
Section 153CSection 69

erred in confirming addition without referring to any incrementing document. Besides, he has not referred to any incriminating material in the satisfaction note issued to the Appellant. 3. On the facts and circumstances of the case in law, Ld. CIT(A) erred in confirming stand of A.O. for not sharing ... facts and in the circumstances of the case, the N.A learned CIT(A) has erred in upholding the validity of a common satisfaction note recorded for multiple assessment years. The appellant submits that such a consolidated satisfaction is bad in law, since satisfaction under the relevant provisions must be recorded

Juararam Chogaji Purohit, Mumbai vs. DCIT Central Circle 4(2), Mumbai

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

ITA 8191/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

For Appellant: 1. On the facts and circumstances of the case in law
Section 153CSection 69

erred in confirming addition without referring to any incrementing document. Besides, he has not referred to any incriminating material in the satisfaction note issued to the Appellant. 3. On the facts and circumstances of the case in law, Ld. CIT(A) erred in confirming stand of A.O. for not sharing ... facts and in the circumstances of the case, the N.A learned CIT(A) has erred in upholding the validity of a common satisfaction note recorded for multiple assessment years. The appellant submits that such a consolidated satisfaction is bad in law, since satisfaction under the relevant provisions must be recorded

Jabra Ram Purohit, Mumbai vs. DCIT Central Circle 4(2), Mumbai

ITA 6642/MUM/2025[2020-21]Status: DisposedITAT Mumbai26 Feb 2026AY 2020-21

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

For Appellant: 1. On the facts and circumstances of the case in law, Ld. CIT(A)
Section 153CSection 69

erred in confirming addition without referring to any incrementing document. Besides, he has not referred to any incriminating material in the satisfaction note issued to the Appellant. 3. On the facts and circumstances of the case in law, Ld. CIT(A) erred in confirming stand of A.O. for not sharing ... facts and circumstances of the case, the CIT(A) erred in holding that a combined satisfaction note is valid in the eyes of law, as current legal and judicial precedent overwhelmingly requires separate satisfaction notes for each assessment year and/or entity; the recording of a combined or consolidated satisfaction note

Jabra Ram Purohit, Mumbai vs. DCIT, Central Circle 4(2), Mumbai

ITA 6641/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Feb 2026AY 2019-20

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

For Appellant: 1. On the facts and circumstances of the case in law, Ld. CIT(A)
Section 153CSection 69

erred in confirming addition without referring to any incrementing document. Besides, he has not referred to any incriminating material in the satisfaction note issued to the Appellant. 3. On the facts and circumstances of the case in law, Ld. CIT(A) erred in confirming stand of A.O. for not sharing ... facts and circumstances of the case, the CIT(A) erred in holding that a combined satisfaction note is valid in the eyes of law, as current legal and judicial precedent overwhelmingly requires separate satisfaction notes for each assessment year and/or entity; the recording of a combined or consolidated satisfaction note

Fayaz Mohammed, Hyderabad vs. DCIT, Central Circle 2(4), Hyderabad

ITA 1672/HYD/2025[2018-19]Status: DisposedITAT Hyderabad25 Feb 2026AY 2018-19

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha G.

For Appellant: Shri P Murali Mohan Rao, САFor Respondent: Smt.V Koteshwaramma, Sr.AR
Section 132Section 147Section 148Section 153ASection 153CSection 250Section 69

circumstances of the case which is invalid and bad in law. 3. The Ld. CIT(A) ought to have considered that the common satisfaction note was recorded for the assessment years 2014-15 to 2020-21, which is bad in law and therefore, the notice u/s 153C ... completed u/s 153C deserves to be annulled. 4. The Ld. CIT(A) ought to have appreciated that that there is no proper recording of satisfaction note in the appellant's case for invoking the provisions of section 153C of the Act and that consolidated satisfaction note recorded for different assessment

Fayaz Mohammed, Hyderabad vs. DCIT, Central Circle 2(4), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1671/HYD/2025[2017-18]Status: DisposedITAT Hyderabad25 Feb 2026AY 2017-18
Section 132Section 147Section 148Section 153ASection 153CSection 250Section 69

circumstances of the case which is invalid and bad in law. 3. The Ld. CIT(A) ought to have considered that the common satisfaction note was recorded for the assessment years 2014-15 to 2020-21, which is bad in law and therefore, the notice u/s 153C ... completed u/s 153C deserves to be annulled. 4. The Ld. CIT(A) ought to have appreciated that that there is no proper recording of satisfaction note in the appellant's case for invoking the provisions of section 153C of the Act and that consolidated satisfaction note recorded for different assessment

Samiuddin Aslam, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

In the result, all the 4 appeals filed by the assessee are allowed

ITA 1225/HYD/2025[2019-20]Status: DisposedITAT Hyderabad25 Feb 2026AY 2019-20

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1222 To 1225/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2016-17 To 2019-20) Shri Samiudedin Aslam Vs. Asstt. Commissioner Of Hyderabad Income Tax, Central Circle 2(4) Hyderabad Pan: Ckvpa7727F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 22/01/2026 घोषणा की तारीख/Pronouncement: 25/02/2026 आदेश/Order Per. Manjunatha, G. A.M. These Four Appeals Filed By The Assessee Are Directed Against The Separate Assessment Orders Passed By The A. O Under Section 153C R.W.S. 144C(13) Of The Income Tax Act, 1961, All Dated 17/01/2025, For The Assessment. Years 2016-17 To 2019- 20 Respectively. The Assessee Has Raised Similar Grounds For All The Four Assessment Years. Therefore, For The Sake Of Convenience

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 115BSection 132Section 144C(5)Section 153CSection 69Section 69A

Shri Samiuddin Aslam, for A.Ys from 2014-15 to 2020-21.Thereafter, the A.O of the other person (i.e. the assessee Shri Samiuddin Aslam) recorded satisfaction note for initiation of proceedings under section 153C of the Act on 2/8/2022 and issued notice under section 153C of the Act on 03/08/2022. In Page ... total income of the assessee for the A.Ys 2014-15 to 2020-21. Thereafter, the A.O of the other person, the assessee recorded satisfaction note for initiating proceedings under section 153C of the Act, on 02/08/2022 and issued notice under section 153C of the Act dated 3/8/2022. In case

Samiuddin Aslam, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

In the result, all the 4 appeals filed by the assessee are allowed

ITA 1224/HYD/2025[2018-19]Status: DisposedITAT Hyderabad25 Feb 2026AY 2018-19

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1222 To 1225/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2016-17 To 2019-20) Shri Samiudedin Aslam Vs. Asstt. Commissioner Of Hyderabad Income Tax, Central Circle 2(4) Hyderabad Pan: Ckvpa7727F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 22/01/2026 घोषणा की तारीख/Pronouncement: 25/02/2026 आदेश/Order Per. Manjunatha, G. A.M. These Four Appeals Filed By The Assessee Are Directed Against The Separate Assessment Orders Passed By The A. O Under Section 153C R.W.S. 144C(13) Of The Income Tax Act, 1961, All Dated 17/01/2025, For The Assessment. Years 2016-17 To 2019- 20 Respectively. The Assessee Has Raised Similar Grounds For All The Four Assessment Years. Therefore, For The Sake Of Convenience

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 115BSection 132Section 144C(5)Section 153CSection 69Section 69A

Shri Samiuddin Aslam, for A.Ys from 2014-15 to 2020-21.Thereafter, the A.O of the other person (i.e. the assessee Shri Samiuddin Aslam) recorded satisfaction note for initiation of proceedings under section 153C of the Act on 2/8/2022 and issued notice under section 153C of the Act on 03/08/2022. In Page ... total income of the assessee for the A.Ys 2014-15 to 2020-21. Thereafter, the A.O of the other person, the assessee recorded satisfaction note for initiating proceedings under section 153C of the Act, on 02/08/2022 and issued notice under section 153C of the Act dated 3/8/2022. In case