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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

M/S. General Glass Co. P. Ltd., Mumbai vs. DCIT Cen. Cir.-21, Mumbai

In the result, the appeals filed by the Revenue are hereby dismissed and those filed by the assessee are allowed as prayed

ITA 4779/MUM/2006[1996-1997]Status: DisposedITAT Mumbai31 Dec 2024AY 1996-1997

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri B R Baskaran, Hon’Bleit(Ss)A No.60/Mum/2004 For Block Assessment 01.04.1990 To 15.09.2000 Dcit Cent. Circle 21, India Containers, Ltd., Mumbai 157 Maker Chamber, Iv, Nariman Point, Mumbai 400 021. Pan Aaaci2557H (Appellant) (Respondent) It(Ss)A No.62/Mum/2004 For Block Assessment 01.04.1990 To 14.09.2000 Dcit Cent. Circle 21, Jyoti Records Mfg. Ltd., Mumbai 157 Maker Chamber, Iv, Nariman Point, Mumbai 400 021. Pan Aaacj1352M (Appellant) (Respondent) It(Ss)A No.63/Mum/2004 For Block Assessment 01.04.1990 To 15.09.2000 Dcit Cent. Circle 21, General Can Pvt. Ltd., Mumbai 157 Maker Chamber, Iv, Nariman Point, Mumbai 400 021. Pan Aaacg1852B (Appellant) (Respondent) It(Ss)A No.64/Mum/2004 For Block Assessment 01.04.1990 To 14.09.2000 Dcit Cent. Circle 21, Shamvik Agrotech Pvt. Ltd., Mumbai 157 Maker Chamber, Iv, Nariman Point, Mumbai 400 021. Pan Aaacs7869L (Appellant) (Respondent)

been complied with. The Bench on such an application had directed the Revenue to produce the record pertaining to the satisfaction note by an order dated 19.11.2008. It appears that inspite of seeking time repeatedly, the satisfaction note was not produced and, eventually, vide order sheet entry dated 18.04.2011 final ... High Court on 01.09.2023 in the following terms : “1. The counsels appearing for the respective Petitioners state that the Revenue does not have the satisfaction note and hence the situation will be similar to that covered by the order that this Court passed on 28th July 2023 in Writ Petition

DCIT Cent. Cir. - 21, Mumbai vs. M/S. Shamvik Glasstech P. Ltd., Mumbai

In the result, the appeals filed by the Revenue are hereby dismissed and those filed by the assessee are allowed as prayed

ITA 3794/MUM/2005[2000-2001]Status: DisposedITAT Mumbai31 Dec 2024AY 2000-2001

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri B R Baskaran, Hon’Bleit(Ss)A No.60/Mum/2004 For Block Assessment 01.04.1990 To 15.09.2000 Dcit Cent. Circle 21, India Containers, Ltd., Mumbai 157 Maker Chamber, Iv, Nariman Point, Mumbai 400 021. Pan Aaaci2557H (Appellant) (Respondent) It(Ss)A No.62/Mum/2004 For Block Assessment 01.04.1990 To 14.09.2000 Dcit Cent. Circle 21, Jyoti Records Mfg. Ltd., Mumbai 157 Maker Chamber, Iv, Nariman Point, Mumbai 400 021. Pan Aaacj1352M (Appellant) (Respondent) It(Ss)A No.63/Mum/2004 For Block Assessment 01.04.1990 To 15.09.2000 Dcit Cent. Circle 21, General Can Pvt. Ltd., Mumbai 157 Maker Chamber, Iv, Nariman Point, Mumbai 400 021. Pan Aaacg1852B (Appellant) (Respondent) It(Ss)A No.64/Mum/2004 For Block Assessment 01.04.1990 To 14.09.2000 Dcit Cent. Circle 21, Shamvik Agrotech Pvt. Ltd., Mumbai 157 Maker Chamber, Iv, Nariman Point, Mumbai 400 021. Pan Aaacs7869L (Appellant) (Respondent)

been complied with. The Bench on such an application had directed the Revenue to produce the record pertaining to the satisfaction note by an order dated 19.11.2008. It appears that inspite of seeking time repeatedly, the satisfaction note was not produced and, eventually, vide order sheet entry dated 18.04.2011 final ... High Court on 01.09.2023 in the following terms : “1. The counsels appearing for the respective Petitioners state that the Revenue does not have the satisfaction note and hence the situation will be similar to that covered by the order that this Court passed on 28th July 2023 in Writ Petition