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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

Deputy Commissioner of Income Tax Central Circle-2, Ludhiana vs. Ab Alcobev Private Limited, Delhi

In the result, appeals of Revenue are dismissed, Cross

ITA 360/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh01 Sept 2025AY 2020-21

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos.356, 357, 358 & 360/Chd/2024 निर्धारण वर्ष / A.Y. : 2016-17, 2017-18, 2019-20 & 2020-21 The Dcit, Central Circle-2, Ludhiana. Vs Ab Alcobev Pvt. Ltd., 154, 1St Floor, Aggarwal Plaza-1, Anandvas Shakurpur, North West, Delhi. अपीलार्थी/Appellant स्थायी लेखा सं./Pan No: Aalca0327J प्रत्यर्थी/Respondent & C.O. Nos.17 To 20/Chd/2025 In

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT DR
Section 132Section 153ASection 153CSection 153DSection 249Section 253Section 3Section 5

another letter, dated 10.09.2021 placed at pages 176 to 177 and asked for copy of the search warrant and the Panchnama coupled with the satisfaction note in the case of assessee company. 1.6 The Ld. Assessing Officer vide letter, dated 24.09.2021, copy placed at pages 171 to 172, mentioned that ... record his satisfaction exhibiting the fact that income pertaining to other assessee has escaped assessment. Thereafter, he would transmit that seized material alongwith his satisfaction note to the AO having territorial jurisdiction over such other person, the AO of the other person would also record his satisfaction and issue notice

Deputy Commissioner of Income Tax, Central Circle-2, Ludhiana vs. Ab Alcobev Private Limited, Delhi

In the result, appeals of Revenue are dismissed, Cross

ITA 358/CHANDI/2024[2019-20]Status: DisposedITAT Chandigarh01 Sept 2025AY 2019-20

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos.356, 357, 358 & 360/Chd/2024 निर्धारण वर्ष / A.Y. : 2016-17, 2017-18, 2019-20 & 2020-21 The Dcit, Central Circle-2, Ludhiana. Vs Ab Alcobev Pvt. Ltd., 154, 1St Floor, Aggarwal Plaza-1, Anandvas Shakurpur, North West, Delhi. अपीलार्थी/Appellant स्थायी लेखा सं./Pan No: Aalca0327J प्रत्यर्थी/Respondent & C.O. Nos.17 To 20/Chd/2025 In

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT DR
Section 132Section 153ASection 153CSection 153DSection 249Section 253Section 3Section 5

another letter, dated 10.09.2021 placed at pages 176 to 177 and asked for copy of the search warrant and the Panchnama coupled with the satisfaction note in the case of assessee company. 1.6 The Ld. Assessing Officer vide letter, dated 24.09.2021, copy placed at pages 171 to 172, mentioned that ... record his satisfaction exhibiting the fact that income pertaining to other assessee has escaped assessment. Thereafter, he would transmit that seized material alongwith his satisfaction note to the AO having territorial jurisdiction over such other person, the AO of the other person would also record his satisfaction and issue notice

Deputy Commissioner of Income Tax Central Circle-2, Ludhiana vs. Ab Alcobev Private Limited, Delhi

In the result, appeals of Revenue are dismissed, Cross

ITA 357/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh01 Sept 2025AY 2017-18

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos.356, 357, 358 & 360/Chd/2024 निर्धारण वर्ष / A.Y. : 2016-17, 2017-18, 2019-20 & 2020-21 The Dcit, Central Circle-2, Ludhiana. Vs Ab Alcobev Pvt. Ltd., 154, 1St Floor, Aggarwal Plaza-1, Anandvas Shakurpur, North West, Delhi. अपीलार्थी/Appellant स्थायी लेखा सं./Pan No: Aalca0327J प्रत्यर्थी/Respondent & C.O. Nos.17 To 20/Chd/2025 In

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT DR
Section 132Section 153ASection 153CSection 153DSection 249Section 253Section 3Section 5

another letter, dated 10.09.2021 placed at pages 176 to 177 and asked for copy of the search warrant and the Panchnama coupled with the satisfaction note in the case of assessee company. 1.6 The Ld. Assessing Officer vide letter, dated 24.09.2021, copy placed at pages 171 to 172, mentioned that ... record his satisfaction exhibiting the fact that income pertaining to other assessee has escaped assessment. Thereafter, he would transmit that seized material alongwith his satisfaction note to the AO having territorial jurisdiction over such other person, the AO of the other person would also record his satisfaction and issue notice

Deputy Commissioner of Income Tax Central Circle-2 Ludhiana, Ludhiana vs. Ab Alcobev Private Limited, Delhi

In the result, appeals of Revenue are dismissed, Cross

ITA 356/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh01 Sept 2025AY 2016-17

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos.356, 357, 358 & 360/Chd/2024 निर्धारण वर्ष / A.Y. : 2016-17, 2017-18, 2019-20 & 2020-21 The Dcit, Central Circle-2, Ludhiana. Vs Ab Alcobev Pvt. Ltd., 154, 1St Floor, Aggarwal Plaza-1, Anandvas Shakurpur, North West, Delhi. अपीलार्थी/Appellant प्रत्यर्थी/Respondent स्थायी लेखा सं./Pan No: Aalca0327J & C.O. Nos.17 To 20/Chd/2025 In

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT DR
Section 132Section 153ASection 153CSection 153DSection 249Section 253Section 3Section 5

another letter, dated 10.09.2021 placed at pages 176 to 177 and asked for copy of the search warrant and the Panchnama coupled with the satisfaction note in the case of assessee company. 1.6 The Ld. Assessing Officer vide letter, dated 24.09.2021, copy placed at pages 171 to 172, mentioned that ... record his satisfaction exhibiting the fact that income pertaining to other assessee has escaped assessment. Thereafter, he would transmit that seized material alongwith his satisfaction note to the AO having territorial jurisdiction over such other person, the AO of the other person would also record his satisfaction and issue notice