← All Phrases

“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

DCIT Central Circle 7 1, Mumbai vs. Royal India Corporation Limited, Mumbai

In the result, all the appeals of the Revenue are dismissed

ITA 4742/MUM/2024[2019-20]Status: DisposedITAT Mumbai29 Jan 2025AY 2019-20

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 131Section 133ASection 153ASection 153C

account of excessive claim of employee benefit expenses, addition on account of excessive claim of expenses etc. None of these additions were based on satisfaction note or incriminating material. 6. Ld. CIT(A) has quashed the order u/s.153C has held as under:- “18. It may be noted here that ... material found pertaining to the F. Ys. 2009-10, 2010-11 & 2011-12 (relevant to A.Ys. 2010-11, 2011-12 & 2012- 13) in the satisfaction note. The assessee contended that invoking of Section 153C of the Act for A.Y 2015-16, for which no incriminating material was found, was arbitrary

Arti Dhall, New Delhi vs. DCIT Central Circle-31, New Delhi

In the result, appeal of the Assessee is partly allowed as

ITA 1239/DEL/2024[2021-22]Status: DisposedITAT Delhi28 Jan 2025AY 2021-22

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraआ.अ.सं/.I.T.A No.1239/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22

Section 132Section 143(3)Section 153CSection 153C(1)Section 45

Assessing Officer, in the present cases, is the same as in the case of the person searched which fact is evident from the satisfaction notes which have been framed by him both as the AO of the person searched and that of the other person i.e. the appellant ... same. It is submitted that based on the above satisfaction note, the AO was inclined to reopen the assessment for seven AY’s i.e. AY 2015- 16 to AY 2021-22. But having done so, the Ld AO, despite recording a satisfaction u/s 153C, opted to proceed with the assessment

Ats Real Estate Builders Private Limited, New Delhi vs. DCIT, Circle-1(1), Delhi

The appeal is allowed

ITA 1207/DEL/2024[2020-21]Status: DisposedITAT Delhi27 Jan 2025AY 2020-21

Bench: SHRI VIKAS AWASTHY (Judicial Member), SHRI NAVEEN CHANDRA (Accountant Member)

For Appellant: Dr. Rakesh Gupta, AdvocateFor Respondent: Ms Amisha S. Gupta, CIT-DR
Section 153C

order were allegedly found which were said to be “belonging” to the assessee and based upon these documents, the jurisdiction was assumed by recording ‘Satisfaction Note’ dt. 7.6.2017 and by issuing notice u/s 153C of the Act, on 13.06.2017. 2.1. The facts of the case, material on record and arguments ... 153C of the Act and which according to the ld. Counsel was not assumed in accordance with law. His emphasis was on the ‘Satisfaction Note’, which is reproduced at page 46 of order of ld.CIT(A) and on various grounds it was alleged to be lacking essentials of a valid

The Modern Construction Co. Pvt. Ltd., Ahmedabad vs. ITO, Ward-2(1)(4), Ahmedabad

The appeal of the assessee is allowed for statistical

ITA 432/AHD/2019[2013-14]Status: DisposedITAT Ahmedabad23 Jan 2025AY 2013-14

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Tushar Hemani, Sr.AdvocateFor Respondent: Dr. Darsi Suman Ratnam, CIT-DR
Section 132Section 153ASection 153CSection 250(6)Section 271(1)(c)

which was a necessary prerequisite for assuming jurisdiction u/s 153C of the Act. More specifically, he stated, that the absence of clarity in the satisfaction note of the AO was with respect to how the documents in his possession from the search conducted on “SCL” had any bearing on determination ... income of the assessee. His contention was that the satisfaction note only mentioned certain documents relating to the assessee which was found during the search on "SCL”, but how those documents had an impact on the determination of the income of the assessee was not coming out from the satisfaction

The United Builders Corporation, Ahmedabad vs. Dy.CIT, Central Circle-1(1), Ahmedabad

The appeal of the assessee is allowed for statistical

ITA 3465/AHD/2016[2013-14]Status: DisposedITAT Ahmedabad23 Jan 2025AY 2013-14

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

Section 132Section 153ASection 153CSection 250(6)Section 271(1)(c)

which was a necessary prerequisite for assuming jurisdiction u/s 153C of the Act. More specifically, he stated, that the absence of clarity in the satisfaction note of the AO was with respect to how the documents in his possession from the search conducted on “SCL” had any bearing on determination ... income of the assessee. His contention was that the satisfaction note only mentioned certain documents relating to the assessee which was found during the search on "SCL”, but how those documents had an impact on the determination of the income of the assessee was not coming out from the satisfaction

Modern Construction Co. Pvt. Ltd., Ahmedabad vs. The Dy.CIT, Central Circle-1(1), Ahmedabad

The appeal of the assessee is allowed for statistical

ITA 3464/AHD/2016[2013-14 (Q-4)]Status: DisposedITAT Ahmedabad23 Jan 2025

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Tushar Hemani, Sr.AdvocateFor Respondent: Dr. Darsi Suman Ratnam, CIT-DR
Section 132Section 153ASection 153CSection 250(6)Section 271(1)(c)

which was a necessary prerequisite for assuming jurisdiction u/s 153C of the Act. More specifically, he stated, that the absence of clarity in the satisfaction note of the AO was with respect to how the documents in his possession from the search conducted on “SCL” had any bearing on determination ... income of the assessee. His contention was that the satisfaction note only mentioned certain documents relating to the assessee which was found during the search on "SCL”, but how those documents had an impact on the determination of the income of the assessee was not coming out from the satisfaction

Partistha Commercial Centre Private Limited, Delhi vs. Commissioner of Income Tax (Appeals), Delhi

ITA 4264/DEL/2024[2016-17]Status: DisposedITAT Delhi23 Jan 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

withdrawals have been made. It is to be examined and verified the source and utilisation of these cash deposits and withdrawals. The said satisfaction note prepared by the AO of the person searched has been kept on record. noted/written therein. After examination of these documents, I am also satisfied that ... only remaining technical ground is that satisfaction u/s 153C is defective especially to the extent that it does not mention "bearing" in the satisfaction note. In this regard, my humble submission for kind consideration are as under: 2. Section 153C starts with non-obstante clause relating to normal assessment procedure

Assistant Commissioner of Income Tax, Central Circle-2, Trichy vs. Ramasamy Natarajan, Trichy

In the result, both the appeals stand dismissed

ITA 2641/CHNY/2024[2015-16]Status: DisposedITAT Chennai22 Jan 2025AY 2015-16

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकरअपील सं./ Ita No.2641/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2015-16) Acit Shri Ramasamy Natarajan बनाम Central Circle-2 # 255, Ganapathy Nagar South, / Vs. Trichy. T.V. Kovil Trichy-620005. "थायीलेखासं./ जीआइआरसं./Pan/Gir No. Aabpn-8486-E (अपीलाथ"/Appellant) : (" थ" / Respondent) & 2. आयकरअपील सं./ Ita No.2640/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2016-17) Acit Shri Jayaraman Muthureddiar बनाम #14, Akila Gardens, 1St Street, Central Circle-2 Trichy. Ganapathy Nagar, T.V.Kovil / Vs. Trichy-620005. "थायीलेखासं./ जीआइआरसं./Pan/Gir No. Aadhj-0819-D (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओर से/ Revenue By : Shri R. Clement Ramesh Kumar (Cit)-Ld. Dr " थ" की ओर से/ Assessee By : Shri Y. Sridhar (Fca) & Ms. Varshha Sridhar (Ca)-Ld. Ars सुनवाई की तारीख/Date Of Hearing : 02-01-2025 घोषणा की तारीख /Date Of Pronouncement : 22-01-2025 आदेश / O R D E R

For Appellant: Shri Y. Sridhar (FCA) & Ms. VarshhaFor Respondent: Shri R. Clement Ramesh Kumar (CIT)-Ld. DR
Section 131Section 132Section 143(3)Section 153CSection 69

During that search, the residence of key individual Smt. R. Ezhilarasi was also covered wherein certain incriminating documents were found and seized. After recording satisfaction note duly approved by the JCIT, notice u/s 153C was issued to the assessee on 04-09-2019. The assessee filed return of income admitting ... assessee and the interest received by the assessee. The employee also explained entries in the documents, modus operandi and sequence of transactions. In the satisfaction note, it has clearly been brought out by Ld. AO that the said document had bearing on determination of total income of the assessee. Therefore

Assistant Commissioner of Income Tax, Central Circle-2, Trichy vs. Jayaraman Muthureddiar, Trichy

In the result, both the appeals stand dismissed

ITA 2640/CHNY/2024[2016-17]Status: DisposedITAT Chennai22 Jan 2025AY 2016-17

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकरअपील सं./ Ita No.2641/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2015-16) Acit Shri Ramasamy Natarajan बनाम Central Circle-2 # 255, Ganapathy Nagar South, / Vs. Trichy. T.V. Kovil Trichy-620005. "थायीलेखासं./ जीआइआरसं./Pan/Gir No. Aabpn-8486-E (अपीलाथ"/Appellant) : (" थ" / Respondent) & 2. आयकरअपील सं./ Ita No.2640/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2016-17) Acit Shri Jayaraman Muthureddiar बनाम #14, Akila Gardens, 1St Street, Central Circle-2 Trichy. Ganapathy Nagar, T.V.Kovil / Vs. Trichy-620005. "थायीलेखासं./ जीआइआरसं./Pan/Gir No. Aadhj-0819-D (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओर से/ Revenue By : Shri R. Clement Ramesh Kumar (Cit)-Ld. Dr " थ" की ओर से/ Assessee By : Shri Y. Sridhar (Fca) & Ms. Varshha Sridhar (Ca)-Ld. Ars सुनवाई की तारीख/Date Of Hearing : 02-01-2025 घोषणा की तारीख /Date Of Pronouncement : 22-01-2025 आदेश / O R D E R

For Appellant: Shri Y. Sridhar (FCA) & Ms. VarshhaFor Respondent: Shri R. Clement Ramesh Kumar (CIT)-Ld. DR
Section 131Section 132Section 143(3)Section 153CSection 69

During that search, the residence of key individual Smt. R. Ezhilarasi was also covered wherein certain incriminating documents were found and seized. After recording satisfaction note duly approved by the JCIT, notice u/s 153C was issued to the assessee on 04-09-2019. The assessee filed return of income admitting ... assessee and the interest received by the assessee. The employee also explained entries in the documents, modus operandi and sequence of transactions. In the satisfaction note, it has clearly been brought out by Ld. AO that the said document had bearing on determination of total income of the assessee. Therefore

DCIT, New Delhi vs. Smt. Usha Sharma, New Delhi

In the result, the appeal filed by the assessee is allowed

ITA 466/DEL/2015[2012-13]Status: DisposedITAT Delhi22 Jan 2025AY 2012-13

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2019-20 Revelation Unique Retail & Vs. Assistant Commissioner Of Income Marketing Private Ltd., Tax, Central Circle-3, 5A/3A, Ansari Road, Daryaganj, Delhi New Delhi Pin: 1100 02 Pan :Aaicr9933L (Appellant) (Respondent)

Section 115BSection 127Section 132Section 142(1)Section 153CSection 234BSection 234CSection 250Section 272A(1)(d)Section 274

grossly erred in not rendering the notice issued under Section 153C and consequent assessment bad in law as the satisfaction note recorded by the Ld. AO is invalid, bad in law and void ab initio; 3. That on the facts and circumstances of the case no addition can be made ... appellant/assessee submitted that Ld. CIT(A) grossly erred in not rendering notice under Section 153C and consequent assessment bad in law as the satisfaction note recorded is bad in law, and void-ab-initio on following counts: i. The said satisfaction note does not provide the details of the documents

Ram Babu Jhalani, Jaipur vs. ITO, Ward 1(4), Jaipur

ITA 1218/JPR/2024[2012-13]Status: DisposedITAT Jaipur21 Jan 2025AY 2012-13

Bench: Him. 2.1 At The Outset Of Hearing, The Bench Observed That There Is Delay Of 151 Days In Filing Of The Appeal By The Assessee For Which The Ld. Ar Of The Assessee Filed Application For Seeking Condonation Of Delay, With Following Prayers & The Assessee To This Effect Also Filed An Affidavit Also :-

For Appellant: Sh. Mukesh Khandelwal, C.AFor Respondent: Ms. Alka Gautam, CIT (Th. V.C.)
Section 147Section 250

obtained by Ms. Sunita Shekhawat from Shri Ram Babu Jhalani. 5 Ram Babu Jhalani vs. ITO Based on this information a satisfaction note u/s 147 of the Act was recorded and got approved from the Pr. Commissioner of Income- Tax, 1, Jaipur vide letter dated 29.03.2019 to issue notice

Nitin Goel, Ghaziabad vs. Income Tax Officer, Ward 2(2)(5), Ghaziabad

In the result, appeal of the assessee is allowed

ITA 3142/DEL/2024[2012-13]Status: DisposedITAT Delhi21 Jan 2025AY 2012-13

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 143(2)Section 153CSection 250

associates and during the course of search, certain documents were found and seized. Based on the entries found noted in one diary, a satisfaction note is recoded that the documents pertained to the assessee and contained entries related to the assessee and proceedings u/s 153C were initiated in the case ... written with “d” were treated as cash payment received by the assessee and addition was made on this account. Ld.AR submits that in the satisfaction note recorded, it is not mentioned by the AO that these documents contained the entries which “have bearing on the total income of the assessee

Maksat Technologies Pvt. Ltd., Delhi vs. DCIT, Circle 16(1), Delhi

In the result the appeal of the assessee is allowed for statistical purpose

ITA 143/DEL/2022[2019-20]Status: DisposedITAT Delhi20 Jan 2025AY 2019-20

Bench: Sh. M. Balaganesh & Sh. Sudhir Kumarassessment Year: 2015-16 M/S Trenchless Engineering Vs. Dcit Services Private Limited Central Circle – 06 C-185, 2Nd Floor Phase-Ii, New Delhi Mayapuri, Delhi 110064 Pan No. Aabct3284 F (Appellant) (Respondent)

Section 132Section 139Section 143(3)Section 153Section 153CSection 68Section 69Section 69C

income was assessed u/s 143(3) of the Act vide order dated 27- 12-2017 and return income was accepted. The AO recorded the satisfaction note on 24-03-2021 and notice issued u/s 153C of the Act on 26-03-2021. In the response of the notice the assessee

Deputy Commissioner of Income Tax, Central Cirlce-2, Ludhiana vs. Rawalpindi Co-Op Cinema Society Ltd, Ludhiana

In the result, the Appeal filed by the department stands dismissed

ITA 552/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh15 Jan 2025AY 2018-19

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 180/Chd/2024 "नधा"रण वष" / Assessment Year : 2018-19 Rawalpindi Co-Op Vs. The Dcit, बनाम Cinema Society Ltd., Central Circle-2, Society Cinema, Ludhiana Ludhiana 141008 "थायी लेखा सं./Pan No: Aaaar0233K अपीलाथ"/ Appellant ""यथ"/ Repsondent & आयकर अपील सं./ Ita No. 552/Chd/2024 "नधा"रण वष" / Assessment Year : 2018-19 The Dcit, Vs. Rawalpindi Co-Op Cinema Central Circle-2, बनाम Society Ltd., Ludhiana Society Cinema, Ludhiana 141008 "थायी लेखा सं./Pan No: Aaaar0233K अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Hybrid Hearing) "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 03.12.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 15.01.2025

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Kusum Bansal, CIT DR
Section 153C

third person other than the Assessee and said incriminating material should have been transmitted to the Assessing Officer of the Assessee along with his satisfaction note demonstrating that income of the Assessee has escaped assessment. Ld. Counsel for the Assessee emphasized that Assessing Officer has not referred any material which ... issue and reserve the order. However, the Bench deemed 180 & 552-Chd-2024 – Rawalpindi Coop Cinema Society ltd., Ludhiana 10 it appropriate that if satisfaction note would have been placed on the record, then it will be helpful to the Bench for deciding the issue justifiably. Therefore, exercising powers under

Rawalpindi Co-Op Cinema Society Limited Society Cinema Ludhiana, Punjab, Ludhiana, Punab vs. The Deputy Commissioner of Income Tax Central Circle-2, Ludhiana, Punjab

In the result, the Appeal filed by the department stands dismissed

ITA 180/CHANDI/2024[2018-2019]Status: DisposedITAT Chandigarh15 Jan 2025AY 2018-2019

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 180/Chd/2024 "नधा"रण वष" / Assessment Year : 2018-19 Rawalpindi Co-Op Vs. The Dcit, बनाम Cinema Society Ltd., Central Circle-2, Society Cinema, Ludhiana Ludhiana 141008 "थायी लेखा सं./Pan No: Aaaar0233K अपीलाथ"/ Appellant ""यथ"/ Repsondent & आयकर अपील सं./ Ita No. 552/Chd/2024 "नधा"रण वष" / Assessment Year : 2018-19 The Dcit, Vs. Rawalpindi Co-Op Cinema Central Circle-2, बनाम Society Ltd., Ludhiana Society Cinema, Ludhiana 141008 "थायी लेखा सं./Pan No: Aaaar0233K अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Hybrid Hearing) "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 03.12.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 15.01.2025

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Kusum Bansal, CIT DR
Section 153C

third person other than the Assessee and said incriminating material should have been transmitted to the Assessing Officer of the Assessee along with his satisfaction note demonstrating that income of the Assessee has escaped assessment. Ld. Counsel for the Assessee emphasized that Assessing Officer has not referred any material which ... issue and reserve the order. However, the Bench deemed 180 & 552-Chd-2024 – Rawalpindi Coop Cinema Society ltd., Ludhiana 10 it appropriate that if satisfaction note would have been placed on the record, then it will be helpful to the Bench for deciding the issue justifiably. Therefore, exercising powers under

Brij Raj Singh Rathaur, New Delhi vs. Addl. CIT, New Delhi

Appeal is dismissed in above terms

ITA 1762/DEL/2011[2006-07]Status: DisposedITAT Delhi15 Jan 2025AY 2006-07

Bench: Sh. Satbeer Singh Godara, Judicial Member & Sh. M. Balaganesh (Accountant Member)

Section 153CSection 68Section 69A

crucial in establishing the existence of undisclosed income in the hands of the Assessee. 3. That the CIT(A) erred in holding that the satisfaction note does not have any reference of the said search while the same clearly establishes a nexus between the seized material and the undisclosed income

Pradyumna Agros Private Limited, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 1033/HYD/2024[2020-21]Status: DisposedITAT Hyderabad10 Jan 2025AY 2020-21

Bench: Shri Manjunatha G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.1033/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2020-21) Pradyumna Agro Private Vs. Acit Limited Central Circle-2(4) Hyderabad Hyderabad [Pan : Aajcp4282H] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri M.V.Prasad & Shri K.S.Rajendra Kumar, Ar Shri Srinath Sadanala, Dr सुिवधई की तधरीख/Date Of Hearing: 09/12/2024 घोर्णध की तधरीख/Date Of 10/01/2025 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 17.09.2024 Of The Learned Commissioner Of Income Tax (Appeals) [Ld.Cit(A)]-12, Hyderabad, Pertaining To A.Y.2020-21 On The Following Grounds : 1. The Order Of The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad Is Erroneous & Opposed To The Facts Of The Case & Law.

For Appellant: Shri M.V.Prasad &
Section 132Section 153CSection 153C(1)Section 69

provisions of section 153C(1) of the Act for the said assessment year. 3. The Ld.CIT(A) ought to have considered that the satisfaction note recorded by the Assessing Officer to enable him to assume jurisdiction u/s 153C is invalid in law as it is completely silent regarding the reasons ... Ld.CIT(A), the appellant challenged the jurisdiction of the Assessing Officer in assuming jurisdiction for assessment of income for the A.Y.2020-21, in light of satisfaction note recorded by the Assessing Officer for initiation of proceedings u/s 153C of the Act. The appellant had also challenged the additions made

ACIT, Muzaffarnagar vs. M/S Rana Iron & Power Ltd., Muzaffarnagar

ITA 4185/DEL/2012[2008-09]Status: DisposedITAT Delhi10 Jan 2025AY 2008-09

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

For Appellant: Sh. Pranshu Singhal, CA &For Respondent: Sh. Jitender Singh, CIT-DR
Section 132Section 132ASection 139Section 143(3)Section 147Section 148Section 149Section 151Section 153Section 153A

BATCH OF WRIT PETITIONS CO Nos. 182 to 184/Del/2025 Arun Agarwal 86. In the present batch, List I pertains to writ petitions which have Satisfaction Notes recorded or section 153C notices issued between the period 01 April 2021 to 31 March 2022. Undisputedly, the First Proviso to section I53C ... writ petitions, learned counsels for respective sides had addressed submissions based on the assumption that it would be the date of issuance of the Satisfaction Note by the AO of the non- searched person and in the case of non-availability of such a note, the date of issuance

DCIT, Ghaziabad vs. M/S. Devidayal Aluminium Industries Pvt. Ltd., Ghaziabad

ITA 4297/DEL/2016[2013-14]Status: DisposedITAT Delhi08 Jan 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

withdrawals have been made. It is to be examined and verified the source and utilisation of these cash deposits and withdrawals. The said satisfaction note prepared by the AO of the person searched has been kept on record. noted/written therein. After examination of these documents, I am also satisfied that ... only remaining technical ground is that satisfaction u/s 153C is defective especially to the extent that it does not mention "bearing" in the satisfaction note. In this regard, my humble submission for kind consideration are as under: 2. Section 153C starts with non-obstante clause relating to normal assessment procedure

DCIT, Ghaziabad vs. M/S. Devidayal Aluminium Industries Pvt. Ltd., Ghaziabad

In the result, appeal of the Revenue is dismissed

ITA 3850/DEL/2016[2007-08]Status: DisposedITAT Delhi08 Jan 2025AY 2007-08

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

Section 132(4)Section 143(2)Section 153CSection 250

five firms of around 242 crores which were bogus in nature and no actual work was done by these firms. Accordingly, in the satisfaction note recorded by the AO wherein the he has observed expenditure relating to the LANCO are bogus and needs further verification and for this purpose proceedings ... siphoned off. 4. The Ld. CIT(A) has erred on facts and in law by holding that incriminating material on the basis of which satisfaction note was drawn by the AO, does not pertain to A.Υ 2016-17 whereas the incriminating material clearly indicates that the assessee company