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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

Homelife Buildcon Private Limited, Sunview Enclave, Ayali Kalan, Ludhiana, Punjab vs. Smt. Samandeep Kaur DCIT-Central Circle-1, Ludhiana, Punjab

In the result, Revenue appeal is dismissed and appeal filed by the assessee is allowed

ITA 880/CHANDI/2024[2021-2022]Status: DisposedITAT Chandigarh17 Jul 2025AY 2021-2022

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 880/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 Homelife Buildcon Private Limited Sunview Enclave, Ayali Kalan, Ludhiana, Punjab-142027 स्थायी लेखा सं./PAN NO: AABCH5690M अपीलार्थी/Appellant बनाम The DCIT Central Circle-1 Ludhiana, Punjab प्रत्यर्थी/Respondent आयकर अपील सं. / ITA No. 1036/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 बनाम Homelife Buildcon Private Limited Sunview Enclave, Ayali

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rohit Kapoor, C.AFor Respondent: Shri Manav Bansal, CIT, DR
Section 115BSection 153D

mandatory conditions prescribed under Section 148, read with Explanation 2 to clause (iv) thereof, particularly by failing to record a valid and proper satisfaction note prior to initiating proceedings based on documents allegedly seized from another premises-such recording being a sine qua non for using such material against ... parties and not from material found in the premises of the applicant. It is contended that such reliance, in the absence of a proper satisfaction note recorded by the AO under section 147, establishing that the material belongs to the appellant, and without obtaining prior approval from

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Homelife Buildcon Pvt. Ltd., Ludhiana

In the result, Revenue appeal is dismissed and appeal filed by the assessee is allowed

ITA 1036/CHANDI/2024[2021-22]Status: DisposedITAT Chandigarh17 Jul 2025AY 2021-22

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 880/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 Homelife Buildcon Private Limited Sunview Enclave, Ayali Kalan, Ludhiana, Punjab-142027 स्थायी लेखा सं./PAN NO: AABCH5690M अपीलार्थी/Appellant The DCIT Central Circle-1 Ludhiana, Punjab प्रत्यर्थी/Respondent आयकर अपील सं. / ITA No. 1036/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 Homelife Buildcon Private Limited Sunview Enclave, Ayali Kalan, Lu

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rohit Kapoor, C.AFor Respondent: Shri Manav Bansal, CIT, DR
Section 115BSection 153D

mandatory conditions prescribed under Section 148, read with Explanation 2 to clause (iv) thereof, particularly by failing to record a valid and proper satisfaction note prior to initiating proceedings based on documents allegedly seized from another premises-such recording being a sine qua non for using such material against ... parties and not from material found in the premises of the applicant. It is contended that such reliance, in the absence of a proper satisfaction note recorded by the AO under section 147, establishing that the material belongs to the appellant, and without obtaining prior approval from

Amico Textiles, Solan vs. DCIT CC-1, Chandigarth

The appeal stand allowed in terms of our above order

ITA 430/CHANDI/2022[2013-14]Status: DisposedITAT Chandigarh15 Jul 2025AY 2013-14

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.430/Chandi/2022 (िनधा"रणवष" / Assessment Year: 2013-14) M/S Amico Textiles Dcit Village Bir Plassi, Ropar Road, Central Circle-1 बनाम/ Vs. Nalagarh, Solan Chandigarh Himachal Pradesh 176077 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaqfa-9823-K (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Neeraj Jain (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Manav Bansal (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 23-06-2025 घोषणाकीतारीख /Date Of Pronouncement : 15-07-2025. आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2013-14 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-3, Gurgaon [Cit(A)] Dated 31-03-2022 In The Matter Of An Assessment Framed By Ld. Ao U/S 147 R.W.S. 153A Of The Act On 17-12- 2018. The Assessee Is Aggrieved By Confirmation Of Addition Of Rs.46.87 Lacs.

For Appellant: Sh. Neeraj Jain (CA) – Ld. ARFor Respondent: Sh. Manav Bansal (CIT) – Ld. DR
Section 139Section 147Section 148Section 149Section 151Section 153Section 153ASection 153CSection 68

Taxman.com 123) quashed the assessment on the ground that that the same ought to have been framed u/s 153C for which recording of satisfaction note would be required. We find that the case before us has identical facts. The material as used against the assessee has been found during search ... solely based on the seized material only. In such a case, the assessment ought to have been framed u/s 153C for which recording of satisfaction note would be a mandatory statutory requirement. No such satisfaction note has been shown to us. Even otherwise, the assessment has been framed