“ satisfaction note ”

CIT v. Calcutta Knitwears

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.

362 ITR 673 · 2014 · Supreme Court

528

ARN Infrastructure India Ltd. v. Asstt. CIT

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.

394 ITR 569 · 2017 · High Court

282

PCIT v. Ojjus Medicare (P) Ltd.

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.

465 ITR 101 · 2024 · High Court

277

DCIT v. Sunil Kumar Sharma

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).

159 Taxmann.com 179 · 2024 · High Court

269

Pepsico India Holdings (P) Ltd. v. ACIT

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.

370 ITR 295 · 2015 · High Court

249

Manish Maheshwari v. ACIT

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.

289 ITR 341 · 2007 · Supreme Court

237

Pepsi Foods (P.) Ltd. v. Asstt. CIT

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.

367 ITR 112 · 2014 · High Court

225

ITA 4991/DEL/2024[2015-16]Status: DisposedITAT Delhi17 Apr 2025AY 2015-16

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

Assistant Commissioner of Income Tax, New Delhi vs. Kinetic Communications Limited, Pune, Maharashtra

The appeal of the Revenue is dismissed

Bench: Shri Anubhav Sharma & Shri Avdhesh Kumar Mishraassessment Year: 2015-16 Acit, Vs Kinetic Communications Ltd., Central Circle-15, G-92, D-Iii Block, Midc, New Delhi. Chinchwad, Pune. Pan: Aaack7632B Co No.18/Del/2025 (Ita No.4991/Del/2024) Assessment Year: 2015-16 Kinetic Communications Ltd., Vs. Acit, G-92, D-Iii Block, Midc, Central Circle-15, Chinchwad, New Delhi. Pune. Pan: Aaack7632B (Appellant) (Respondent) Assessee By : Shri Pawan Jain, Ca Revenue By : Shri Dayainder Singh Sidhu, Cit-Dr Date Of Hearing : 17.04.2025 Date Of Pronouncement : 17.04.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Revenue Against The Order Dated 16.08.2024 Of The Commissioner Of Income-Tax (Appeals)-26, New Delhi Co No.18/Del/2025 (Hereinafter Referred To As The Ld. First Appellate Authority Or ‘The Ld. Faa’, For Short) In Appeal No.10641/2014-15 Arising Out Of The Appeal Before It Against The Order Dated 28.03.2023 Passed U/S 153C R.W.S. 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) By The Acit, Central Circle- 15, New Delhi (Hereinafter Referred To As The Ld. Ao). The Assessee Has Filed The Cross Objection.

For Appellant: Shri Pawan Jain, CAFor Respondent: Shri Dayainder Singh Sidhu, CIT-DR

Section 132Section 153Section 153ASection 153CSection 153C(1)

jurisdictional ground which, could be raised by the assessee. Coming to the merits of that ground, learned senior counsel submitted that the Satisfaction Note dated April 18, 2007 is ex facie recorded/prepared by the AO in his capacity as the AO of the assessee society and does ... with in the capacity of AO of the assessee society, but this cannot be earlier than April 18, 2007, i.e. the date when the Satisfaction Note was prepared. Since the Assessment Order pursuant thereto 4 CO No.18/Del/2025 can be passed under Section 153A(1) of the Act for a period

Shyamsunder Bang, New Delhi vs. ACIT Central Circel 8, New Delhi

In the result, the Appeal of the Assessee is allowed

ITA 1887/DEL/2023[2016-17]Status: DisposedITAT Delhi17 Apr 2025AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Brajesh Kumar Singhshyam Sunder Bang Vs. Acit M-6, Greater Kailsah Part Central Circle 8 2, New Delhi Ara Centre, Jhandewalan Pan: Aafpb2321L Extension, New Delhi Appellant Respondent Assessee By Sh. Rohit Tiwari, Adv & Ms. Tanya, Adv Revenue By Ms. Jaya Chaudhary, Cit(Dr) Date Of Hearing 27/02/2025 Date Of Pronouncement 17/04/2025 Order

Section 132Section 139(1)Section 143(2)Section 153CSection 154Section 69B

ACIT 3. Because the conflicting notice issued by the Mumbai Tax Authority and the assessment made by the Delhi Tax Authority. 4. Because the satisfaction note recorded and satisfied by Ld. DCIT Mumbai it self bad on the face of it. 5. Because transferring of jurisdiction without giving any opportunity

Shiv Milk Products, Meerut vs. ITO, Ward- 2(3), Meerut

The appeals of the assessee are allowed and that of the Revenue is dismissed

ITA 2342/DEL/2018[2010-11]Status: DisposedITAT Delhi16 Apr 2025AY 2010-11

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

For Appellant: Shri Salil AggarwaL, Sr. AdvocateFor Respondent: Shri Mahesh Kumar, CIT-DR

Section 153A(1)Section 153CSection 153C(1)

Group of companies and key office bearers of the assessee on 05.10.2017, wherein allegedly incriminating evidences were discovered and, on the basis of the satisfaction note in search and seizure action, notice u/s 153C of the Act was issued in case of the assessee ... have to be determined. On the admitted facts, it comes up that notices u/s 153C were issued on 26.09.2019 and, if recording of the satisfaction note and receiving of record from the assessing officer of the searched person is considered as 26.09.2019, the search year in the case

Dakshayani Horticulture Private Limited, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

In the result, ITA.No.1333/Hyd

ITA 1333/HYD/2024[2019-20]Status: DisposedITAT Hyderabad09 Apr 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

Section 1Section 132Section 143(2)Section 153CSection 153DSection 263

153C by the Assessing Officer is vitiated in the absence of recording of any valid satisfaction for the instant assessment year in the satisfaction note with reference to the specific seized material which has a bearing on the determination of total income for the said year. 5. On the facts ... seized material relied on by him in the revision order and ignoring the seized material adverted to by the Assessing Officer in the satisfaction note which relates to A.Υ 2017-18, for the purpose of rendering the finding that the seized material relied on by him has a bearing

Satyanarayana Reddy Manne, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

In the result, appeal of the Assessee is allowed

ITA 1332/HYD/2024[2018-19]Status: DisposedITAT Hyderabad09 Apr 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA MV Prasad and Shri KS Rajendra KumarFor Respondent: Shri B. Bala Krishna, CIT-DR

Section 132Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 153CSection 153DSection 263

completed the search assessments of the appellant u/s 153A of the Act for A.Ys 2015-16 to 2020-21. Further, the AO recorded consolidated satisfaction notes u/s 153C for A.Ys 2015-16 to 2021-22 in the cases of the eight group companies which purchased the lands at Rangareddyguda, based ... case of MSN Laboratories Ltd and its associated concerns and completed the assessments u/s 153C for the said assessment years. In the satisfaction notes of the eight group companies, the AO recorded that the on-money payments for purchase of lands at Rangareddyguda were made during

Adrija Farms Private Limited, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

In the result, ITA.No.1333/Hyd

ITA 1331/HYD/2024[2019-20]Status: DisposedITAT Hyderabad09 Apr 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

Section 1Section 132Section 143(2)Section 153CSection 153DSection 263

Spark Vidyuth Private Limited, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

In the result, ITA.No.1322 & 1323/Hyd

ITA 1330/HYD/2024[2018-19]Status: DisposedITAT Hyderabad09 Apr 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

ITA 1329/HYD/2024[2017-18]Status: DisposedITAT Hyderabad09 Apr 2025AY 2017-18

153C by the Assessing Officer is vitiated in the absence of recording of any valid satisfaction for the instant assessment year in the satisfaction note with reference to the specific seized material which has a bearing on the determination of total income for the said year. 5. On the facts ... prior approval of JCIT u/sec.153D, revisionary powers of PCIT u/sec.263 of the Act are unsustainable in law and (ii) In absence of a valid satisfaction note, assumption of jurisdiction u/sec.153C by the Assessing Officer is bad in law and void ab initio. The Learned Counsel for the Assessee submitted that

Spark Vidyuth Private Limited, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

In the result, ITA.No.1322 & 1323/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Respondent: ShriB. Bala Krishna, CIT-DR

ITA 1328/HYD/2024[2019-20]Status: DisposedITAT Hyderabad09 Apr 2025AY 2019-20

153C by the Assessing Officer is vitiated in the absence of recording of any valid satisfaction for the instant assessment year in the satisfaction note with reference to the specific seized material which has a_ bearing on_ the determination of total income for the said year. . On the facts ... prior approval of JCIT u/sec.153D, revisionary powers of PCIT u/sec.263 of the Act are unsustainable in law and (ii) In absence of a valid satisfaction note, assumption of jurisdiction u/sec.153C by the Assessing Officer is bad in law and void ab initio. The Learned Counsel for the Assessee submitted that

Prayaga Green Meadows Private Limited, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

In the result, ITA.No.1333/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

Section 1Section 132Section 143(2)Section 153CSection 153DSection 263

Prathima Eggsel Private Limited, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

In the result, ITA.No.1322 & 1323/Hyd

ITA 1327/HYD/2024[2018-19]Status: DisposedITAT Hyderabad09 Apr 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

ITA 1326/HYD/2024[2017-18]Status: DisposedITAT Hyderabad09 Apr 2025AY 2017-18

153C by the Assessing Officer is vitiated in the absence of recording of any valid satisfaction for the instant assessment year in the satisfaction note with reference to the specific seized material which has a bearing on the determination of total income for the said year. 5. On the facts ... prior approval of JCIT u/sec.153D, revisionary powers of PCIT u/sec.263 of the Act are unsustainable in law and (ii) In absence of a valid satisfaction note, assumption of jurisdiction u/sec.153C by the Assessing Officer is bad in law and void ab initio. The Learned Counsel for the Assessee submitted that

Prathima Eggsel Private Limited, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

In the result, ITA.No.1322 & 1323/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

ITA 1325/HYD/2024[2018-19]Status: DisposedITAT Hyderabad09 Apr 2025AY 2018-19

153C by the Assessing Officer is vitiated in the absence of recording of any valid satisfaction for the instant assessment year in the satisfaction note with reference to the specific seized material which has a bearing on the determination of total income for the said year. 5. On the facts ... prior approval of JCIT u/sec.153D, revisionary powers of PCIT u/sec.263 of the Act are unsustainable in law and (ii) In absence of a valid satisfaction note, assumption of jurisdiction u/sec.153C by the Assessing Officer is bad in law and void ab initio. The Learned Counsel for the Assessee submitted that

Prathima Resorts & Restaurants Private Limited, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

In the result, ITA.No.1322 & 1323/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Respondent: ShriB. Bala Krishna, CIT-DR

ITA 1324/HYD/2024[2017-18]Status: DisposedITAT Hyderabad09 Apr 2025AY 2017-18

153C by the Assessing Officer is vitiated in the absence of recording of any valid satisfaction for the instant assessment year in the satisfaction note with reference to the specific seized material which has a_ bearing on_ the determination of total income for the said year. . On the facts ... prior approval of JCIT u/sec.153D, revisionary powers of PCIT u/sec.263 of the Act are unsustainable in law and (ii) In absence of a valid satisfaction note, assumption of jurisdiction u/sec.153C by the Assessing Officer is bad in law and void ab initio. The Learned Counsel for the Assessee submitted that

Prathima Resorts & Restaurants Private Limited, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

In the result, ITA.No.1322 & 1323/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

ITA 1323/HYD/2024[2018-19]Status: DisposedITAT Hyderabad09 Apr 2025AY 2018-19

153C by the Assessing Officer is vitiated in the absence of recording of any valid satisfaction for the instant assessment year in the satisfaction note with reference to the specific seized material which has a bearing on the determination of total income for the said year. 5. On the facts ... prior approval of JCIT u/sec.153D, revisionary powers of PCIT u/sec.263 of the Act are unsustainable in law and (ii) In absence of a valid satisfaction note, assumption of jurisdiction u/sec.153C by the Assessing Officer is bad in law and void ab initio. The Learned Counsel for the Assessee submitted that

Msn Institute of Medical Sciences Private Limited, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

In the result, ITA.No.1322 & 1323/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

ITA 1322/HYD/2024[2017-18]Status: DisposedITAT Hyderabad09 Apr 2025AY 2017-18

153C by the Assessing Officer is vitiated in the absence of recording of any valid satisfaction for the instant assessment year in the satisfaction note with reference to the specific seized material which has a bearing on the determination of total income for the said year. 5. On the facts ... prior approval of JCIT u/sec.153D, revisionary powers of PCIT u/sec.263 of the Act are unsustainable in law and (ii) In absence of a valid satisfaction note, assumption of jurisdiction u/sec.153C by the Assessing Officer is bad in law and void ab initio. The Learned Counsel for the Assessee submitted that

Msn Institute of Medical Sciences Private Limited, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

In the result, ITA.No.1322 & 1323/Hyd

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Respondent: ShriB. Bala Krishna, CIT-DR