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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

Greenwood Resorts Private Limited, Guwahati vs. Deputy Commissioner of Income Tax, Guwahati

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

ITA 110/GTY/2024[2014-15]Status: DisposedITAT Guwahati29 May 2025AY 2014-15

Bench: Shri Manomohan Das & Shri Rakesh Mishra

Section 153CSection 250Section 36Section 40A(3)Section 68

appellant a survey was conducted and the Ld. AO assumed jurisdiction u/s 153C of the Act. Our attention was drawn to the satisfaction note as per paper book pages 1 to 5. It was contended that the Assessing Officer of the searched person recorded the finding of the search proceeding ... details are at page 4 para 2.1 of the paper book. In the paper book, pages 1 to 5 contain copy of the satisfaction note. It was submitted that the property was purchased on 17.11.2015 and section 56(2)(x) of the Act was not on the statute

Shamsuddin, Kochi vs. ACIT, Central Circle 1, Kochi

In the result, all the appeals filed by the assessee stand partly allowed

ITA 96/COCH/2025[2018-19]Status: DisposedITAT Cochin29 May 2025AY 2018-19

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Am

For Appellant: Ms. Divya Ravindran, AdvocateFor Respondent: Shri Sundarasan S., CIT-DR
Section 132Section 139(1)Section 143(3)Section 153Section 153C

argument raised by the appellant in this regard lacks credibility and hence not sustainable. 11. However, the CIT(A), without referring to the satisfaction note recorded by the AOs of both the searched party as well as the appellant, merely recorded this finding. It must be made clear that

Shamsuddin, Kochi vs. ACIT, Central Circle 1, Kochi

In the result, all the appeals filed by the assessee stand partly allowed

ITA 95/COCH/2025[2015-16]Status: DisposedITAT Cochin29 May 2025AY 2015-16

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Am

For Appellant: Ms. Divya Ravindran, AdvocateFor Respondent: Shri Sundarasan S., CIT-DR
Section 132Section 139(1)Section 143(3)Section 153Section 153C

argument raised by the appellant in this regard lacks credibility and hence not sustainable. 11. However, the CIT(A), without referring to the satisfaction note recorded by the AOs of both the searched party as well as the appellant, merely recorded this finding. It must be made clear that

Shamsuddin, Kochi vs. ACIT, Central Circle 1, Kochi

In the result, all the appeals filed by the assessee stand partly allowed

ITA 94/COCH/2025[2014-15]Status: DisposedITAT Cochin29 May 2025AY 2014-15

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Am

For Appellant: Ms. Divya Ravindran, AdvocateFor Respondent: Shri Sundarasan S., CIT-DR
Section 132Section 139(1)Section 143(3)Section 153Section 153C

argument raised by the appellant in this regard lacks credibility and hence not sustainable. 11. However, the CIT(A), without referring to the satisfaction note recorded by the AOs of both the searched party as well as the appellant, merely recorded this finding. It must be made clear that

Shamsuddin, Kochi vs. ACIT, Central Circle 1, Kochi

In the result, all the appeals filed by the assessee stand partly allowed

ITA 93/COCH/2025[2013-14]Status: DisposedITAT Cochin29 May 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Am

For Appellant: Ms. Divya Ravindran, AdvocateFor Respondent: Shri Sundarasan S., CIT-DR
Section 132Section 139(1)Section 143(3)Section 153Section 153C

argument raised by the appellant in this regard lacks credibility and hence not sustainable. 11. However, the CIT(A), without referring to the satisfaction note recorded by the AOs of both the searched party as well as the appellant, merely recorded this finding. It must be made clear that

Kunna Padi Abdul Nazar, Kannur vs. ACIT, Central Circle 2, Kozhikode

In the result, all the appeals filed by the assessee stand partly allowed

ITA 92/COCH/2025[2018-19]Status: DisposedITAT Cochin29 May 2025AY 2018-19

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Am

For Appellant: Smt. Divya Ravindran, AdvocateFor Respondent: Shri Sundarasan S., CIT-DR
Section 132Section 139(1)Section 153Section 153C

argument raised by the appellant in this regard lacks credibility and hence not sustainable. 11. However, the CIT(A), without referring to the satisfaction note recorded by the AOs of both the searched party as well as the appellant, merely recorded this finding. It must be made clear that

Kunna Padi Abdul Nazar, Kannur vs. ACIT, Central Circle 2, Kozhikode

In the result, all the appeals filed by the assessee stand partly allowed

ITA 91/COCH/2025[2017-18]Status: DisposedITAT Cochin29 May 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Am

For Appellant: Smt. Divya Ravindran, AdvocateFor Respondent: Shri Sundarasan S., CIT-DR
Section 132Section 139(1)Section 153Section 153C

argument raised by the appellant in this regard lacks credibility and hence not sustainable. 11. However, the CIT(A), without referring to the satisfaction note recorded by the AOs of both the searched party as well as the appellant, merely recorded this finding. It must be made clear that

Kunna Padi Abdul Nazar, Kannur vs. ACIT, Central Circle 2, Kozhikode

In the result, all the appeals filed by the assessee stand partly allowed

ITA 90/COCH/2025[2016-17]Status: DisposedITAT Cochin29 May 2025AY 2016-17

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Am

For Appellant: Smt. Divya Ravindran, AdvocateFor Respondent: Shri Sundarasan S., CIT-DR
Section 132Section 139(1)Section 153Section 153C

argument raised by the appellant in this regard lacks credibility and hence not sustainable. 11. However, the CIT(A), without referring to the satisfaction note recorded by the AOs of both the searched party as well as the appellant, merely recorded this finding. It must be made clear that

Kunna Padi Abdul Nazar, Kannur vs. ACIT, Central Circle 2, Kozhikode

In the result, all the appeals filed by the assessee stand partly allowed

ITA 89/COCH/2025[2015-16]Status: DisposedITAT Cochin29 May 2025AY 2015-16

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Am

For Appellant: Smt. Divya Ravindran, AdvocateFor Respondent: Shri Sundarasan S., CIT-DR
Section 132Section 139(1)Section 153Section 153C

argument raised by the appellant in this regard lacks credibility and hence not sustainable. 11. However, the CIT(A), without referring to the satisfaction note recorded by the AOs of both the searched party as well as the appellant, merely recorded this finding. It must be made clear that

Kunna Padi Abdul Nazar, Kannur vs. ACIT, Central Circle 2, Kozhikode

In the result, all the appeals filed by the assessee stand partly allowed

ITA 88/COCH/2025[2014-15]Status: DisposedITAT Cochin29 May 2025AY 2014-15

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Am

For Appellant: Smt. Divya Ravindran, AdvocateFor Respondent: Shri Sundarasan S., CIT-DR
Section 132Section 139(1)Section 153Section 153C

argument raised by the appellant in this regard lacks credibility and hence not sustainable. 11. However, the CIT(A), without referring to the satisfaction note recorded by the AOs of both the searched party as well as the appellant, merely recorded this finding. It must be made clear that

Kunna Padi Abdul Nazar, Kannur vs. ACIT, Central Circle 2, Kozhikode

In the result, all the appeals filed by the assessee stand partly allowed

ITA 87/COCH/2025[2013-14]Status: DisposedITAT Cochin29 May 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Am

For Appellant: Smt. Divya Ravindran, AdvocateFor Respondent: Shri Sundarasan S., CIT-DR
Section 132Section 139(1)Section 153Section 153C

argument raised by the appellant in this regard lacks credibility and hence not sustainable. 11. However, the CIT(A), without referring to the satisfaction note recorded by the AOs of both the searched party as well as the appellant, merely recorded this finding. It must be made clear that

Chozhiyattel Muhammed Nizar, Malappuram vs. ACIT, Central Circle-1, Kochi

In the result, all the appeals filed by the assessee stand partly allowed

ITA 40/COCH/2025[2015-16]Status: DisposedITAT Cochin29 May 2025AY 2015-16

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav., Jm

For Appellant: Shri Suresh Kumar C., CAFor Respondent: Shri Sundarasan S. CIT-DR
Section 132Section 153Section 153C

argument raised by the appellant in this regard lacks credibility and hence not sustainable. 11. However, the CIT(A), without referring to the satisfaction note recorded by the AOs of both the searched party as well as the appellant, merely recorded this finding. It must be made clear that

Chozhiyattel Muhammed Nizar, Malappuram vs. ACIT, Central Circle-1, Kochi

In the result, all the appeals filed by the assessee stand partly allowed

ITA 39/COCH/2025[2014-15]Status: DisposedITAT Cochin29 May 2025AY 2014-15

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav., Jm

For Appellant: Shri Suresh Kumar C., CAFor Respondent: Shri Sundarasan S. CIT-DR
Section 132Section 153Section 153C

argument raised by the appellant in this regard lacks credibility and hence not sustainable. 11. However, the CIT(A), without referring to the satisfaction note recorded by the AOs of both the searched party as well as the appellant, merely recorded this finding. It must be made clear that

M/S. Eagle Traders & Logistics, Bellary vs. Deputy Commissioner of Income Tax, Central Circle- 2(3), Bangalore

Accordingly, the appeals filed by the assessee are allowed in above terms

ITA 237/BANG/2020[2011-12]Status: DisposedITAT Bangalore29 May 2025AY 2011-12

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. Prashanth G S, CAFor Respondent: Ms. Neha Sahay, JCIT(DR)(ITAT), Bangalore
Section 132(1)(a)Section 132(2)Section 153ASection 153CSection 153DSection 292B

mandatory condition of recording of satisfaction under section 153C of the Act has not been complied with or having complied, copy of satisfaction note has not been provided to the appellant and thus the assessment has no legs to stand the test of law. e) The orders of the authorities ... been complied with. Alternatively, it is submitted that even if such satisfaction has been recorded, a copy of the satisfaction note has not been furnished to the appellant, thereby rendering the assessment proceedings legally unsustainable.During the course of the appellate hearing, the learned Authorised Representative submitted that, assuming without admitting

M/S. Eagle Traders & Logistics, Bellary vs. Deputy Commissioner of Income Tax, Central Circle- 2(3), Bangalore

Accordingly, the appeals filed by the assessee are allowed in above terms

ITA 236/BANG/2020[2010-11]Status: DisposedITAT Bangalore29 May 2025AY 2010-11

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. Prashanth G S, CAFor Respondent: Ms. Neha Sahay, JCIT(DR)(ITAT), Bangalore
Section 132(1)(a)Section 132(2)Section 153ASection 153CSection 153DSection 292B

mandatory condition of recording of satisfaction under section 153C of the Act has not been complied with or having complied, copy of satisfaction note has not been provided to the appellant and thus the assessment has no legs to stand the test of law. e) The orders of the authorities ... been complied with. Alternatively, it is submitted that even if such satisfaction has been recorded, a copy of the satisfaction note has not been furnished to the appellant, thereby rendering the assessment proceedings legally unsustainable.During the course of the appellate hearing, the learned Authorised Representative submitted that, assuming without admitting

M/S. Eagle Traders & Logistics, Bellary vs. Deputy Commissioner of Income Tax, Central Circle- 2(3), Bangalore

ITA 235/BANG/2020[2009-10]Status: DisposedITAT Bangalore29 May 2025AY 2009-10

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. Prashanth G S, CAFor Respondent: Ms. Neha Sahay, JCIT(DR)(ITAT), Bangalore
Section 132(1)(a)Section 132(2)Section 153ASection 153CSection 153DSection 292B

mandatory condition of recording of satisfaction under section 153C of the Act has not been complied with or having complied, copy of satisfaction note has not been provided to the appellant and thus the assessment has no legs to stand the test of law. e) The orders of the authorities ... been complied with. Alternatively, it is submitted that even if such satisfaction has been recorded, a copy of the satisfaction note has not been furnished to the appellant, thereby rendering the assessment proceedings legally unsustainable.During the course of the appellate hearing, the learned Authorised Representative submitted that, assuming without admitting

M/S. Eagle Traders & Logistics, Bellary vs. Deputy Commissioner of Income Tax, Central Circle- 2(3), Bangalore

Accordingly, the appeals filed by the assessee are allowed in above terms

ITA 234/BANG/2020[2008-09]Status: DisposedITAT Bangalore29 May 2025AY 2008-09

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. Prashanth G S, CAFor Respondent: Ms. Neha Sahay, JCIT(DR)(ITAT), Bangalore
Section 132(1)(a)Section 132(2)Section 153ASection 153CSection 153DSection 292B

mandatory condition of recording of satisfaction under section 153C of the Act has not been complied with or having complied, copy of satisfaction note has not been provided to the appellant and thus the assessment has no legs to stand the test of law. e) The orders of the authorities ... been complied with. Alternatively, it is submitted that even if such satisfaction has been recorded, a copy of the satisfaction note has not been furnished to the appellant, thereby rendering the assessment proceedings legally unsustainable.During the course of the appellate hearing, the learned Authorised Representative submitted that, assuming without admitting

Rameshwer Dass, Delhi vs. DCIT, Central Circle-3, New Delhi

The appeals are allowed

ITA 248/DEL/2020[2017-18]Status: DisposedITAT Delhi28 May 2025AY 2017-18

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaitas No.241, 242 & 248/Del/2020 Assessment Years: 2015-16, 2016-17 & 2017-18 Mr. Rameshwer Das, Vs Dcit, 5873, Top Floor, Central Circle-3, Malka Ganj Chowk, New Delhi. Jawahar Nagar, Delhi. Pan: Aaapd2587R (Appellant) (Respondent) Assessee By : Shri Rajiv Khandelwal, Ca & Shri Jaind Kumar Jaiswal, Advocate Revenue By : Ms Rajinder Kaur, Cit-Dr Date Of Hearing : 22.04.2025 Date Of Pronouncement : 28.05.2025 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Dated 31.10.2019 Of The Commissioner Of Income-Tax (Appeals)-23, New Delhi (Hereinafter Referred To As Ld. First Appellate Authority Or In Short Ld. ‘Faa’) In Appeals No.38/2019-20, 39/2019-20 & 40/2019-20 Arising Out Of The Appeals Before It Against The Orders Dated 30.12.2018 Passed U/S 153C R.W.S. 153A Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By The Dcit, Central Circle-03, New Delhi (Hereinafter Referred To As The Ld. Ao).

For Appellant: Shri Rajiv Khandelwal, CA &For Respondent: Ms Rajinder Kaur, CIT-DR
Section 143(3)Section 153CSection 153D

amongst other grounds on merits, and questioning the assumption of jurisdiction u/s 153C of the Act, which assessee alleged to be on a satisfaction note not having relevant material to show the extent of undisclosed income for relevant years we find there is an additional ground raised by the assessee ... additional ground pertaining to wrongful assumption of jurisdiction is admitted and we find that admitted state of affairs is that satisfaction note for assumption of jurisdiction u/s 153C of the Act was prepared by ld. AO of assessee on 22.3.2018. Thus the assessment for this AY 2017-18 should

Rameshwer Dass, Delhi vs. DCIT, Central Circle-3, New Delhi

The appeals are allowed

ITA 242/DEL/2020[2016-17]Status: DisposedITAT Delhi28 May 2025AY 2016-17

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaitas No.241, 242 & 248/Del/2020 Assessment Years: 2015-16, 2016-17 & 2017-18 Mr. Rameshwer Das, Vs Dcit, 5873, Top Floor, Central Circle-3, Malka Ganj Chowk, New Delhi. Jawahar Nagar, Delhi. Pan: Aaapd2587R (Appellant) (Respondent) Assessee By : Shri Rajiv Khandelwal, Ca & Shri Jaind Kumar Jaiswal, Advocate Revenue By : Ms Rajinder Kaur, Cit-Dr Date Of Hearing : 22.04.2025 Date Of Pronouncement : 28.05.2025 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Dated 31.10.2019 Of The Commissioner Of Income-Tax (Appeals)-23, New Delhi (Hereinafter Referred To As Ld. First Appellate Authority Or In Short Ld. ‘Faa’) In Appeals No.38/2019-20, 39/2019-20 & 40/2019-20 Arising Out Of The Appeals Before It Against The Orders Dated 30.12.2018 Passed U/S 153C R.W.S. 153A Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By The Dcit, Central Circle-03, New Delhi (Hereinafter Referred To As The Ld. Ao).

For Appellant: Shri Rajiv Khandelwal, CA &For Respondent: Ms Rajinder Kaur, CIT-DR
Section 143(3)Section 153CSection 153D

amongst other grounds on merits, and questioning the assumption of jurisdiction u/s 153C of the Act, which assessee alleged to be on a satisfaction note not having relevant material to show the extent of undisclosed income for relevant years we find there is an additional ground raised by the assessee ... additional ground pertaining to wrongful assumption of jurisdiction is admitted and we find that admitted state of affairs is that satisfaction note for assumption of jurisdiction u/s 153C of the Act was prepared by ld. AO of assessee on 22.3.2018. Thus the assessment for this AY 2017-18 should

Rameshwer Dass, Delhi vs. DCIT, Central Circle-3, New Delhi

The appeals are allowed

ITA 241/DEL/2020[2015-16]Status: DisposedITAT Delhi28 May 2025AY 2015-16

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaitas No.241, 242 & 248/Del/2020 Assessment Years: 2015-16, 2016-17 & 2017-18 Mr. Rameshwer Das, Vs Dcit, 5873, Top Floor, Central Circle-3, Malka Ganj Chowk, New Delhi. Jawahar Nagar, Delhi. Pan: Aaapd2587R (Appellant) (Respondent) Assessee By : Shri Rajiv Khandelwal, Ca & Shri Jaind Kumar Jaiswal, Advocate Revenue By : Ms Rajinder Kaur, Cit-Dr Date Of Hearing : 22.04.2025 Date Of Pronouncement : 28.05.2025 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Dated 31.10.2019 Of The Commissioner Of Income-Tax (Appeals)-23, New Delhi (Hereinafter Referred To As Ld. First Appellate Authority Or In Short Ld. ‘Faa’) In Appeals No.38/2019-20, 39/2019-20 & 40/2019-20 Arising Out Of The Appeals Before It Against The Orders Dated 30.12.2018 Passed U/S 153C R.W.S. 153A Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By The Dcit, Central Circle-03, New Delhi (Hereinafter Referred To As The Ld. Ao).

For Appellant: Shri Rajiv Khandelwal, CA &For Respondent: Ms Rajinder Kaur, CIT-DR
Section 143(3)Section 153CSection 153D

amongst other grounds on merits, and questioning the assumption of jurisdiction u/s 153C of the Act, which assessee alleged to be on a satisfaction note not having relevant material to show the extent of undisclosed income for relevant years we find there is an additional ground raised by the assessee ... additional ground pertaining to wrongful assumption of jurisdiction is admitted and we find that admitted state of affairs is that satisfaction note for assumption of jurisdiction u/s 153C of the Act was prepared by ld. AO of assessee on 22.3.2018. Thus the assessment for this AY 2017-18 should