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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

ACIT, Central Circle-18, New Delhi vs. Gaurav Aggarwal, New Delhi

The appeal of the Revenue is dismissed

ITA 6204/DEL/2017[2011-12]Status: DisposedITAT Delhi18 Jun 2025AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2011-12 Acit, Vs Shri Gaurav Aggarwal, Central Circle-18, D-31, Pushpanjali Enclave, New Delhi. Pitampura, New Delhi – 110 034. Co No.13/Del/2021 (Ita No.6204/Del/2017) Assessment Year: 2011-12 Shri Gaurav Aggarwal, Vs. Acit, D-31, Pushpanjali Enclave, Central Circle-18, Pitampura, New Delhi New Delhi – 110 034. (Appellant) (Respondent) Assessee By : Shri Salil Aggarwal, Sr. Advocate; Shri Shailesh Gupta, Ca; Shri Uma Shankar, Advocate; & Shri Madhur Aggarwal, Advocate Revenue By : Shri Kailash Dan Ratnoo, Cit-Dr Date Of Hearing : 30.04.2025 Date Of Pronouncement : 18.06.2025

For Appellant: Shri Salil Aggarwal, Sr. AdvocateFor Respondent: Shri Kailash Dan Ratnoo, CIT-DR
Section 127Section 143(2)Section 143(3)Section 153C

Appeals) has further grossly erred in law and on facts in overlooking the basic fact that no addition was made based on the satisfaction note, and the assessment as contemplated under section 153C is not a denovo assessment and as such the additions so made by assessing officer which ... beyond satisfaction note are liable to be deleted in totality, as the same are outside the scope of assessment made under section 153C of the Act.” 3. It was submitted by the ld. counsel that a search in the case of M/s Jagat Commodities, part of Jagat Group of cases

ACIT, New Delhi vs. M/S. Sea Point Trading & Builders Pvt. Ltd., New Delhi

In the result, the appeal of the assessee is dismissed

ITA 1731/DEL/2016[2012-13]Status: DisposedITAT Delhi18 Jun 2025AY 2012-13

Bench: Ms. Madhumita Roy, Judical Member & Shri Manish Agarwalasst. Commissioner Of M/S. Sea Point Trading & Income Tax, Builders Pvt. Ltd. Central Circle-2, Vs. B-4/43, 2Nd Floor, New Delhi. Safdarjung Enclave, New Delhi-110029. Pan: Aabcs0741C (Appellant) (Respondent) Assessee By Dr. Rakesh Gupta, Adv., Shri Somil Agarwal, Adv. & Shri Deepesh Garg, Adv. Department By Shri Virender Kumar Singh, Sr. Dr Date Of Hearing 07/05/2025 Date Of Pronouncement 18/06/2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Revenue Against The Order Of Learned Commissioner Of Income Tax (Appeals)-23, New Delhi [Ld. Cit(A), In Short], Dt. 29.01.2026 In Appeal No. 16/2015-16 For Assessment Year 2012-13 Passed U/S 250 Of The Income Tax Act, 1961 (The Act, In Short). 2. The Revenue Has Taken The Following Grounds Of Appeal: “1. The Order Of Ld. Cit(A) Is Not Correct In Law & On Facts. 2. On The Facts & Circumstances Of The Case, The Ld. Cit(A) Has Erred In Laws In Deleting The Addition Of Rs.6,35,00,000/- Made By Ao On Account Of Unexplained Cash Credit U/S 68 Of The Act Received From M/S Manan Merchandise Pvt. Ltd.”

Section 127Section 132Section 147Section 148Section 250Section 68

companies which have been mentioned by the AO at pages 2-6 of the assessment order while the AO has himself observed in the satisfaction note that the source of the advances from MMPL are share premiums received in the preceding year, thus giving a finding contradictory to the conclusion