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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

Abdulsami Abdulhamid Zariwala, Surat vs. ITO, Ward 2(3)(3), Surat

In the result, the appeal of the assessee is allowed, for statistical purposes

ITA 95/SRT/2025[2012-13]Status: DisposedITAT Surat21 Oct 2025AY 2012-13

Bench: Shri Diesh Mohan Sinha & Shri Bijayananda Pruseth

For Appellant: Shri Yogesh B Shah, ARFor Respondent: Shri Ajay Uke, Ld. Sr. DR
Section 144Section 148Section 234Section 271(1)(c)Section 271BSection 271FSection 77

Word 2(3)(6) Both have initiated Penal Actions U/s 271B and 271F in their respective orders but the same are initiated without deriving satisfaction Note in their respective orders under appeal. On the facts and in the circumstance of the case, the penalty actions-initiated U/s 271B

Shri Vinay Pratap Singh, Lucknow vs. Astt. Commissioner of Income Tax, Lucknow

In the result, the appeal of the assessee is partly allowed

ITA 688/LKW/2015[2012-13]Status: DisposedITAT Lucknow17 Oct 2025AY 2012-13

Bench: SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Swarn Singh, C.AFor Respondent: Sh. R.K. Agarwal, CIT DR
Section 132Section 143(3)Section 153CSection 153D

Central Circle-21 in ITA No. 2421/DEL/2014 and Manish Maheshwari vs. ACIT 289 ITR 341 SC, wherein it had been laid down that the satisfaction notes had to be recorded in the file of the assessee in whose case action under section 153A was taken. It was submitted that from ... perusal of the copy of the satisfaction note provided by the ld. AO, it could be seen that the proceedings had been initiated under section 153C on the basis of a copy of the assessee’s bank account which had been found at the premises where search was carried

Stercon Energy Pvt. Ltd., Delhi vs. ACIT, Central Circle-29, Delhi

In the result, the appeal of the assessee is allowed

ITA 5798/DEL/2024[2016-17]Status: DisposedITAT Delhi17 Oct 2025AY 2016-17

Bench: SHRI SUDHIR KUMAR (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(3)Section 153C

made by the AO is unjustified, illegal and hence deserves to be deleted. 7. That the Ld. AO has erred in not recording the satisfaction note qua the Assessee herein which has to be independent from the searched person and Ld. CIT(A) has erred in upholding the same ... Himanshu Verma and not of the assessee, therefore, the addition made be deleted on this score. 5. With respect to the satisfaction note recorded, the Ld. AR submits that common satisfaction was recorded for all the assessment years and no incriminating material whatsoever was identified except the statements

Stercon Energy Pvt. Ltd., Delhi vs. ACIT Central Circle- 29, Delhi

In the result, the appeal of the assessee is allowed

ITA 5797/DEL/2024[2017-18]Status: DisposedITAT Delhi17 Oct 2025AY 2017-18

Bench: SHRI SUDHIR KUMAR (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(3)Section 153C

made by the AO is unjustified, illegal and hence deserves to be deleted. 7. That the Ld. AO has erred in not recording the satisfaction note qua the Assessee herein which has to be independent from the searched person and Ld. CIT(A) has erred in upholding the same ... Himanshu Verma and not of the assessee, therefore, the addition made be deleted on this score. 5. With respect to the satisfaction note recorded, the Ld. AR submits that common satisfaction was recorded for all the assessment years and no incriminating material whatsoever was identified except the statements

Stercon Energy Pvt Ltd, Delhi vs. ACIT, Central Circle-29, Delhi

In the result, the appeal of the assessee is allowed

ITA 5796/DEL/2024[2018-19]Status: DisposedITAT Delhi17 Oct 2025AY 2018-19

Bench: SHRI SUDHIR KUMAR (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(3)Section 153C

made by the AO is unjustified, illegal and hence deserves to be deleted. 7. That the Ld. AO has erred in not recording the satisfaction note qua the Assessee herein which has to be independent from the searched person and Ld. CIT(A) has erred in upholding the same ... Himanshu Verma and not of the assessee, therefore, the addition made be deleted on this score. 5. With respect to the satisfaction note recorded, the Ld. AR submits that common satisfaction was recorded for all the assessment years and no incriminating material whatsoever was identified except the statements

Income Tax Officer Ward-1(4), Jaipur vs. Pradeep Kumar Dusad, Jaipur

47. As a result, ITA No

ITA 900/JPR/2025[2016-17]Status: DisposedITAT Jaipur15 Oct 2025AY 2016-17
For Appellant: Sh. S. B. Natani, Ld. C.AFor Respondent: Shri Rajesh Ojha, Ld. CIT
Section 10(38)Section 115BSection 132Section 133ASection 143(3)Section 147Section 148Section 150Section 153CSection 250

Developers, in which the assessee was only a partner. Learned CIT(A) was of the view that in the given facts and circumstances, no satisfaction note under section 153C of the Act could have been drawn against the appellant, and as a result, notice under section 153C issued ... assessee, a partner in the said firm, and to hold that proceedings initiated by the Assessing Officer on the basis of satisfaction note were not proper. Reliance has been placed on the discussion made by the Assessing Officer in the assessment order to contend that the assessment order being well

Pradeep Kumar Dusad, Jaipur vs. Dy. Commissioner of Income Tax Central Circle-2, Jaipur

47. As a result, ITA No

ITA 722/JPR/2025[2016-17]Status: DisposedITAT Jaipur15 Oct 2025AY 2016-17

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. S. B. Natani, Ld. C.AFor Respondent: Shri Rajesh Ojha, Ld. CIT
Section 10(38)Section 115BSection 132Section 133ASection 143(3)Section 147Section 148Section 150Section 153CSection 250

Developers, in which the assessee was only a partner. Learned CIT(A) was of the view that in the given facts and circumstances, no satisfaction note under section 153C of the Act could have been drawn against the appellant, and as a result, notice under section 153C issued ... assessee, a partner in the said firm, and to hold that proceedings initiated by the Assessing Officer on the basis of satisfaction note were not proper. Reliance has been placed on the discussion made by the Assessing Officer Pradeep Kumar Dusad, Jaipur. in the assessment order to contend that

DCIT., Central Circle-1(2), Hyderabad vs. Vpr Mining Infrastructure Private Limited, Nellore

In the result, appeal of the Revenue is dismissed

ITA 939/HYD/2025[2018-19]Status: DisposedITAT Hyderabad15 Oct 2025AY 2018-19

Bench: : Shri Vijay Pal Rao & Shri Manjunatha Gआ.अपी.सं /Ita No.939/Hyd./2025 िनधा"रण वष"/Assessment Year 2018-2019 The Dcit, Central Vpr Mining Vs. Infrastructure Private Circle-1(2), Hyderabad. Limited, Nellore. Pin -500 004. Pin – 524003 Andhra Pradesh Telangana. Pan Aaccv6733A (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Mv Prasad राज" व "ारा/Revenue By:: Dr. Narendra Kumar Naik, Cit-Dr

For Appellant: CA MV PrasadFor Respondent: : Dr. Narendra Kumar Naik, CIT-DR
Section 132Section 143(3)Section 153C

other hand, the learned Authorized Representative Sri MV Prasad, CA for the Assessee has submitted that the Assessing Officer in the satisfaction note 8 ITA.No.939/Hyd./2025 has made a mention of seized material pertains to the financial years 2018-2019 and 2019-2020 i.e., for the assessment years ... case on hand, it is evident that the seized 18 ITA.No.939/Hyd./2025 material/incriminating material as referred by the Assessing Officer in the satisfaction note does not disclose any undisclosed income for the assessment year under consideration and, therefore, in the absence of any incriminating material disclosing any undisclosed income

Naveen Kumar Musinipally, Usa vs. ADIT (Int-Taxn)-1, Hyderabad

In the result, appeal of the Assessee partly

ITA 323/HYD/2024[2016-2017]Status: DisposedITAT Hyderabad15 Oct 2025AY 2016-2017

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: CA, K C DevdasFor Respondent: Sri Posu Babu Alli, Sr. AR
Section 127Section 132Section 142(1)Section 153CSection 2(47)Section 2(47)(v)Section 234A

Officer satisfied that, provisions of the section 153C of the Income Tax Act, 1961 were attracted in the case of the assessee as the satisfaction note recorded u/sec.153C of the Income Tax Act, 1961 [in short “the Act”] had bearing on the total income of the assessee for the assessment

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

In the result, all the appeals filed by the assessee

ITA 4744/MUM/2025[2020-21]Status: DisposedITAT Mumbai15 Oct 2025AY 2020-21

Bench: Hon’Ble Shri Sandeep Gosain & Hon'Ble Shri Girish Agrawal

Section 143(3)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

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

In the result, all the appeals filed by the assessee stands allowed

ITA 4743/MUM/2025[2018-19]Status: DisposedITAT Mumbai15 Oct 2025AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Girish Agrawal

Section 143(3)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

Pravin Khetaram Purohit, Mumbai vs. DCIT, Central Circle 4(2), Mubmai

In the result, all the appeals filed by the assessee

ITA 4742/MUM/2025[2017-18]Status: DisposedITAT Mumbai15 Oct 2025AY 2017-18

Bench: Hon'Ble Shri Sandeep Gosain & Hon'Ble Shri Girish Agrawal

Section 143(3)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

Raghav Kumar, New Delhi vs. ACIT Central Circle-29, New Delhi

In the result, the appeal filed by the assessee being ITA

ITA 3215/DEL/2025[2021-22]Status: DisposedITAT Delhi15 Oct 2025AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

For Appellant: Shri R.S. Singhvi, AdvocateFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 132Section 153CSection 69Section 69A

validity of notice u/s 153C of the Income tax Act, 1961 even though same was not based on any incriminating material. 1.2 That the satisfaction note recorded by the assessing officer is without application of mind and same being based on unsubstantiated allegation drawn notice u/s 153C is illegal ... envelops as appearing at Page 4 of the assessment order does not contain name of the assessee and as such the foundation of satisfaction note is ex-facie absent. The ld. AR also submitted that there is no direct or indirect evidence against the assessee and inference drawn from

Raghav Kumar, Delhi vs. ACIT Central Circle 29, New Delhi

In the result, the appeal filed by the assessee being ITA

ITA 3214/DEL/2025[2020-21]Status: DisposedITAT Delhi15 Oct 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

For Appellant: Shri R.S. Singhvi, AdvocateFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 132Section 153CSection 69Section 69A

validity of notice u/s 153C of the Income tax Act, 1961 even though same was not based on any incriminating material. 1.2 That the satisfaction note recorded by the assessing officer is without application of mind and same being based on unsubstantiated allegation drawn notice u/s 153C is illegal ... envelops as appearing at Page 4 of the assessment order does not contain name of the assessee and as such the foundation of satisfaction note is ex-facie absent. The ld. AR also submitted that there is no direct or indirect evidence against the assessee and inference drawn from

Hiteshi Leasing and Housing Pvt Ltd, New Delho vs. DCIT, Circle-1, Faridabad

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

ITA 4620/DEL/2024[2011-12]Status: DisposedITAT Delhi15 Oct 2025AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarhiteshi Leasing & Housing Pvt. Ltd., Vs. Dcit, Circle 1, Yogi Associates, Faridabad. E – 335, East Of Kailash, New Delhi – 110 005. (Pan : Aaach8298J) (Appellant) (Respondent) Assessee By : Shri Pushpdeep Singh, Advocate Revenue By : Shri Kailash Dan Ratnoo, Cit Dr Date Of Hearing : 28.08.2025 Date Of Order : 15.10.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income-Tax (Appeals), Gurgaon-3 [For Short ‘Ld. Cit (A)] Dated 04.081.2024 For Assessment Year 2011-12 Raising Following Grounds Of Appeal :- “(A) That On The Facts & Circumstances Of The Case The Learned Assessing Officer & Cit(A), While Passing The Order Erred In: A. Passing The Assessment Order Dated 26.03.2015 U/S 153A Despite The Fact The Assessee Was Not Searched & The Assessee Was Issued Notice Under Section 153C On 29.1 1.2013. This Is A Jurisdictional Error

For Appellant: Shri Pushpdeep Singh, AdvocateFor Respondent: Shri Kailash Dan Ratnoo, CIT DR
Section 131Section 153ASection 153CSection 68

recorded reasons/satisfaction which is reproduced at page 2 of the assessment order. For the sake of brevity, the same are reproduced below :- “Reasons Satisfaction note for taking up the case of M/s Hiteshi Leasing & Housing Pt Lid, I2873, Ram Nagar Extension Shahdra, Delhi under section 153C of the Income ... under consideration is an unabated assessment year as the time limit for issuing a notice under section 143(2) expired on 30.09.2012 whereas the satisfaction note is dated 29.11.2013 and the seized material was received by the A.O. of the Assessee on 23.07.20l3 and referred Para

JCIT OSD, Delhi vs. Midas Polypack Pvt Ltd Now Known As Ag Polypack Pvt Ltd, Delhi

In the result, the appeals filed by the Revenue are dismissed

ITA 1349/DEL/2025[2016-17]Status: DisposedITAT Delhi14 Oct 2025AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwalआ.अ.सं/.I.T.A Nos.1347 To 1349/Del/2025 िनधा"रणवष"/Assessment Years:2014-15 To 2016-17 बनाम Jcit (Osd), Midas Polypack Pvt. Ltd., 404, C.R. Building, Vs. (Now Known As Ag Polypack Pvt. Ltd.) I.P. Estate, C-4/1, Rajiv Nagar, Industrial Area, Delhi. Mandoli, Delhi. Pan No.Aaicm3805G अपीलाथ" Appellant ""यथ"/Respondent

Section 153C(1)

assessment under section 153C(1) of the Income-tax Act, 1961, have to be calculated six years prior to the AY in which satisfaction note was recorded by concerned Assessing Officer even when Section 153C(1) of the Act clearly mentions that calculation of block period has to be done

JCIT, OSD, Delhi vs. Midas Polypack Pvt. Ltd Now Known As A G Polypack Pvt. Ltd, Delhi

In the result, the appeals filed by the Revenue are dismissed

ITA 1348/DEL/2025[2015-16]Status: DisposedITAT Delhi14 Oct 2025AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwalआ.अ.सं/.I.T.A Nos.1347 To 1349/Del/2025 िनधा"रणवष"/Assessment Years:2014-15 To 2016-17 बनाम Jcit (Osd), Midas Polypack Pvt. Ltd., 404, C.R. Building, Vs. (Now Known As Ag Polypack Pvt. Ltd.) I.P. Estate, C-4/1, Rajiv Nagar, Industrial Area, Delhi. Mandoli, Delhi. Pan No.Aaicm3805G अपीलाथ" Appellant ""यथ"/Respondent

Section 153C(1)

assessment under section 153C(1) of the Income-tax Act, 1961, have to be calculated six years prior to the AY in which satisfaction note was recorded by concerned Assessing Officer even when Section 153C(1) of the Act clearly mentions that calculation of block period has to be done

JCIT, OSD, Delhi vs. Midas Polypack Pvt Ltd, Now Known As Ag Polypack Pvt Ltd, Delhi

In the result, the appeals filed by the Revenue are dismissed

ITA 1347/DEL/2025[2014-15]Status: DisposedITAT Delhi14 Oct 2025AY 2014-15

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwalआ.अ.सं/.I.T.A Nos.1347 To 1349/Del/2025 िनधा"रणवष"/Assessment Years:2014-15 To 2016-17 बनाम Jcit (Osd), Midas Polypack Pvt. Ltd., 404, C.R. Building, Vs. (Now Known As Ag Polypack Pvt. Ltd.) I.P. Estate, C-4/1, Rajiv Nagar, Industrial Area, Delhi. Mandoli, Delhi. Pan No.Aaicm3805G अपीलाथ" Appellant ""यथ"/Respondent

Section 153C(1)

assessment under section 153C(1) of the Income-tax Act, 1961, have to be calculated six years prior to the AY in which satisfaction note was recorded by concerned Assessing Officer even when Section 153C(1) of the Act clearly mentions that calculation of block period has to be done

Princess Infra & Development LLP, Kota vs. ACIT-Central Circle-Kota, Kota

In the result, both the appeals of the assesseeare allowed for statistical purposes as indicate hereinabove

ITA 859/JPR/2025[2018-19]Status: DisposedITAT Jaipur10 Oct 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Saurav Harsh, AdvocateFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 144Section 153B(1)(b)Section 153CSection 56(2)(X)Section 68

covered under search and survey proceeding carried out by the department Therefore, notice os 1530 was issued to the assessee on 27.09.2019, after recording satisfaction note on dated 24.09 2019. The assessee was centralized to Central Circle-Kota by the Princopal Commissioner of Income-tax, Kota vide his order ... under search and survey proceeding carmed out by the department. Therefore, notice u/s 143(2) was issued to the assessee on 27.09.2019, after recording satisfaction note on dated 24.09.2019. The assessee was centralized to Central Circle-Kota by the Principal Commissioner of Income-tax, Kota vide his order

Princess Infra & Development LLP, Kota vs. ACIT-Central Circle-Kota, Kota

In the result, both the appeals of the assesseeare allowed for statistical purposes as indicate hereinabove

ITA 858/JPR/2025[2016-17]Status: DisposedITAT Jaipur10 Oct 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Saurav Harsh, AdvocateFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 144Section 153B(1)(b)Section 153CSection 56(2)(X)Section 68

covered under search and survey proceeding carried out by the department Therefore, notice os 1530 was issued to the assessee on 27.09.2019, after recording satisfaction note on dated 24.09 2019. The assessee was centralized to Central Circle-Kota by the Princopal Commissioner of Income-tax, Kota vide his order ... under search and survey proceeding carmed out by the department. Therefore, notice u/s 143(2) was issued to the assessee on 27.09.2019, after recording satisfaction note on dated 24.09.2019. The assessee was centralized to Central Circle-Kota by the Principal Commissioner of Income-tax, Kota vide his order