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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

Pareshbhai M Ahendrabhai, Pm Jewelwx P Ltd, Medabad vs. ACIT .Cen . Cir-2, Rajkot

In the result, the appeal of the assessee is allowed

ITA 435/RJT/2024[2018-2019]Status: DisposedITAT Rajkot03 Nov 2025AY 2018-2019

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.435/Rjt/2024 निर्धारणवर्ष /Assessment Year: 2018-19 P.M. Jewelex Pvt. Ltd. (Formerly Known As Pareshbhai 101, Shreeji Balaji Paragon, Nr. Rock Vs. Rewgency Hotel, Opp. Samartheshwar Mahadev, C. G. Road, Ahmedabad, Gujarat - 380009 Pan : Aajcp1915H (अपीलार्थी/Appellant) निर्धारिती की ओर से/Assessee By : Shri S. N. Divatia, Ar राजस्व की ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Sr.Dr सुनवाई की तारीख /Date Of Hearing : 05/08/2025 घोषणा की तारीख/Date Of Pronouncement : 03/11/2025 Order Per Dinesh Mohan Sinha: Captioned Appeal Filed By Assessee Pertaining To Assessment Year 2018-19, Is Directed Against The Order Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) By The Ld. Commissioner Of Income-Tax (Appeal)-11, Ahmedabad (In Short ‘Cit(A)'), Dated 10.05.2024, Which In Turn Arises Out Of Assessment Order Passed By Assessing Officer U/S. 143(3) R.W.S. 153C Of The Act On 19.12.2019.

For Appellant: Shri S. N. Divatia, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr.DR
Section 143(3)Section 153CSection 250Section 69A

Rajkot. One of the consignees was the appellant and therefore, as per the provisions of the Act, the appellant was provided with copies of satisfaction Note and statements recorded. The AO also intimated the Jurisdictional AO of the claimed consignor of gold/Bullion/jewellery i.e. M/s. Akarsh Gold, Ludhiana regarding the seizure ... Gold during post interception Interrogation/investigation. Subsequently, proceedings u/s 153C was initiated in the case of the assessee and AO has also sent the information/his satisfaction note for initiation of proceedings u/s 153C to the jurisdictional AO of the supplier M/s. Akarsh Gold, Ludhiana. 3.2 The AO in the assessment order

Assistant Commissioner of Income Tax, Central Circle-3, Sura, Surat vs. Pipodra Textile Park LLP, Surat

ITA 795/SRT/2024[2018-19]Status: DisposedITAT Surat31 Oct 2025AY 2018-19

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.795/Srt/2024 Assessment Year: (2018-19) (Hybrid Hearing) Acit, Vs. Pipodra Textile Park Llp, S No.85, Vilol. Lindiad, Tal: Central Circle-3, Mangrol, Surat - 395002 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aasfp8206B (Appellant) (Respondent) ""या"ेप सं /Co No.27/Srt/2024 (Ay 2018-19) (A/O Ita No.795/Srt/2024 Pipodra Textile Park Llp Vs. Acit, S No.85, Vilol. Lindiad, Tal: Central Circle-3, Mangrol, Surat– 395 002 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aasfp 8206 B (Co-Objector) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By Shri Ramesh Malpani, Ca राज"वक" ओर से /Respondent By Shri Mukesh Jain, Cit-Dr & Shri Kevin Langaliya, Ca सुनवाई क" तार"ख/Date Of Hearing 03/09/2025 उ"घोषणा क" तार"ख/Date Of Pronouncement 31/10/2025

Section 153CSection 250

assessee is that initiation of proceedings u/s 153C of the Act in its case are not valid because copy of satisfaction note was not provided to him. The CIT(A) has dismissed this ground of assessee by observing that the appellant has not furnished any document showing that any request ... made by it to the AO for supplying copy of satisfaction note. He also observed that there was sufficient material and basis for initiating proceedings u/s 153C of the Act, which were communicated to assessee in the notice issued during assessment proceedings. He, therefore, did not find any merit