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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

Kumar Saurav, Patna vs. DCIT, Central Circle, Noida

The appeal of the assessee is allowed

ITA 5561/DEL/2018[2012-13]Status: DisposedITAT Delhi28 May 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2012-13 Shri Kumar Saurav, Vs Dcit, C/O Shanker Mehta, Central Circle, Naya Gaon, Noida. Guljarbagh, Patna – 800 007. Pan: Cklps6721H (Appellant) (Respondent) Assessee By : Dr. Rakesh Gupta, Advocate & Shri Somil Agarwal, Advocate Revenue By : Shri Dayainder Singh Sidhu, Cit-Dr Date Of Hearing : 07.05.2025 Date Of Pronouncement : 28.05.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Order Dated 23.07.2018 Of The Commissioner Of Income-Tax (Appeals)-Iv, Kanpur (Hereinafter Referred To As The Ld. First Appellate Authority Or ‘The Ld. Faa’, For Short) In Appeal No.Cit(A)-Iv/Knp/11106/244-Dcit-Cc-Noida/2016- 17 Arising Out Of The Appeal Before It Against The Order Dated 28.12.2016 Passed U/S 153C/143(3) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) By The Dcit, Central Circle, Noida (Hereinafter Referred To As The Ld. Ao).

For Appellant: Dr. Rakesh Gupta, Advocate &For Respondent: Shri Dayainder Singh Sidhu, CIT-DR
Section 10(38)Section 132Section 153CSection 68

word as to how and what material content related to the assessee so as to allege that there was suppression of income. The satisfaction note is certainly not worded in accordance with the law requiring the AO assuming jurisdiction u/s 153C of the Act to show that the seized document