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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

Deputy Commissioner of Income Tax, Central Cirlce -3, Coimbatore vs. P P Enterprises, Bengaluru

In the result, appeal filed by the assessee and department are

ITA 2528/CHNY/2024[2016-17]Status: DisposedITAT Chennai09 Feb 2026AY 2016-17

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 नधारण वष/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 नधारण वष/Assessment Years: 2010-11 To 2014-15 & 2016-17 Mr. P. Palanisamy, 390, P.P. Nilayam, 9Th Main I Cross, Hal Ii Stage, Indira Nagar, Bengaluru-560 038. V. The Acit, Central Circle-3, Coimbatore. [Pan:Adspp 9150 F] (अपीलाथ/Appellant) (यथ/Respondent) आयकर अपील सं./Ita Nos.219, 220, 221 & 222/Chny/2025 नधारण वष/Assessment Years: 2015-16, 2010-11, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.200, 201 To 208/Chny/2025 नधारण वष/Assessment Years: 2016-17, 2011-12 To 2018-19 & आयकर अपील सं./Ita Nos.3388 To 3392/Chny/2024 िनधारण वष/Assessment Years: 2014-15 To 2018-19 M/S. P.P. Financers, 24, Radha Avenue, 3Rd Street, Valsaravakkam, Chennai-600 087. V. The Acit, Central Circle-3, Coimbatore. [Pan: Aahfp 0288 L] (अपीलाथ/Appellant) (यथ/Respondent) आयकर अपील सं./Ita Nos.215 To 218 & 223/Chny/2025 िनधारण वष/Assessment Years: 2015-16 To 2018-19 & 2014-15 Mr. P. Kuppuchamy, No.80/7, 17Th Cross, 16Th Main Road, Btm Layout, Ns Palya, Bangaluru-560 076. V. The Acit, Central Circle-3, Coimbatore.

Section 153C

Pushpanjali Constructions (P.) Ltd. v. DCIT [128 ITR (Trib) 201 (Del)], with specific reference to paragraph 23, wherein it was held that a satisfaction note which is general, vague, and casual, without recording particulars of escapement of income, quantification thereof, or linkage to a specific assessment year, reflects lack ... ld.AR, the said examination note is at best a communication seeking approval from the Joint Commissioner, and cannot be equated with a legally valid satisfaction note as contemplated under the statute. 10. The ld.AR also placed reliance on the judgment of the Hon’ble Karnataka High Court in DCIT

DCIT, New Delhi vs. Sh. Kunjan Arora, New Delhi

Accordingly, notice u/s 153C is liable to be quashed and the resultant order framed u/s 153C is also liable to be quashed. We order accordingly. The Cross Objection of the assessee is allowed

ITA 2772/DEL/2014[2009-10]Status: DisposedITAT Delhi09 Feb 2026AY 2009-10

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandradcit, Vs. Kunjan Arora, Central Circle-03, 2A/53, Geeta Colony, New Delhi Delhi (Appellant) (Respondent) Pan: Adkpa3182A Co 77/Del/2024 (In Ita No. 2772/Del/2014) (Assessment Year: 2009-10) Kunjan Arora, Vs. Dcit, 2A/53, Geeta Central Circle-03, Colony, New Delhi Delhi (Appellant) (Respondent) Pan: Adkpa3182A Assessee By : Shri Salil Kapoor, Adv Shri Rajan Malik, Adv Shri Utkarsa Gupta, Adv Revenue By: Ms. Monika Singh, Cit Dr Date Of Hearing 09/02/2026 Date Of Pronouncement 09/02/2026

For Appellant: Shri Salil Kapoor, AdvFor Respondent: Ms. Monika Singh, CIT DR
Section 153C

group of cases on 30.06.2009 where certain documents pertaining to the assessee were found and seized. On the basis of these documents, a satisfaction note was recorded for initiating action u/s 153C of the Act. Notice u/s 153C was issued on 14.06.2011 on the basis of documents seized and addition ... assessee argued that the documents relied upon by the AO which were found during the search on the basis of which satisfaction note u/s 153C was recorded, was unsigned. As the Page 2 of 7 CO 77/Del/2024 Kunjan Arora document was unsigned therefore, the law at that time requiring

Bharati Jayanti Jain, Mumbai vs. ACIT, Central Circle 4(2), Mumbai

ITA 7323/MUM/2025[2017-18]Status: DisposedITAT Mumbai06 Feb 2026AY 2017-18

Bench: Shri Pawan Singh& Shri Arun Khodpia

Section 250Section 254(1)Section 69

specific assessment years for making addition in the absence of date of payment in the extract of excel sheet provided to the appellant vide satisfaction note 5. On the facts and under the circumstances of the case and in law, the learned CIT(A) erred in confirming addition without appreciating

Bharati Jayanti Jain, Mumbai vs. ACIT, Central Circle 4(2), Mumbai

ITA 7322/MUM/2025[2019-20]Status: DisposedITAT Mumbai06 Feb 2026AY 2019-20

Bench: Shri Pawan Singh& Shri Arun Khodpia

Section 250Section 254(1)Section 69

specific assessment years for making addition in the absence of date of payment in the extract of excel sheet provided to the appellant vide satisfaction note 5. On the facts and under the circumstances of the case and in law, the learned CIT(A) erred in confirming addition without appreciating

Bharati Jayanti Jain, Mumbai vs. ACIT Central Circle 4(2), Mumbai

In the result, all the appeals filed by the assessee stands allowed

ITA 7321/MUM/2025[2018-19]Status: DisposedITAT Mumbai06 Feb 2026AY 2018-19

Bench: Shri Pawan Singh& Shri Arun Khodpia

Section 250Section 254(1)Section 69

specific assessment years for making addition in the absence of date of payment in the extract of excel sheet provided to the appellant vide satisfaction note 5. On the facts and under the circumstances of the case and in law, the learned CIT(A) erred in confirming addition without appreciating

Veena Hiralal Mehta, Mumbai vs. DCIT Central Circle 4(2), Mumbai

In the result, both the appeals under consideration stand allowed

ITA 5492/MUM/2025[2018-19]Status: DisposedITAT Mumbai06 Feb 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Bharat Kumar, Ld. CAFor Respondent: Shri Vivek Perampurna, (Ld. CIT- D.R.)
Section 131Section 132Section 153Section 250

submitted that the assessee was provided with the show-cause notice dated 17.01.2024 along with the relevant details and documents. Further, in the satisfaction note, all the details are mentioned and communicated to the assessee, which also contains the Excel sheets, detailing the shop number, area, level, total amount

DCIT Central Circle 1, New Delhi vs. Udai Shanker Awasthi, New Delhi

ITA 5347/DEL/2025[2018-19]Status: DisposedITAT Delhi06 Feb 2026AY 2018-19

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Vinod Kumar Bindal, CAFor Respondent: Ms. Pooja Swaroop, CIT (DR)
Section 132Section 153CSection 68

necessary satisfaction u/s 153C of the Act was recorded on 29-09-2021 by the Learned AO of the assessee on receipt of a satisfaction note dated 25- 09-2021 from the AO of Shri Rajiv Saxena. Thereafter, notices u/s 153C r.w.s. 153A of the Act were issued ... Hence, the date of search qua the assessee herein would be the date of recording of satisfaction note by the Learned AO of the assessee which is 29-09-2021 which falls in Assessment Year 2022-23. Hence applying the ratio decidendi of Hon'ble Delhi High Court referred supra

DCIT Central Circle 1, New Delhi vs. Udai Shanker Awasthi, New Delhi

ITA 5346/DEL/2025[2016-17]Status: DisposedITAT Delhi06 Feb 2026AY 2016-17

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Vinod Kumar Bindal, CAFor Respondent: Ms. Pooja Swaroop, CIT (DR)
Section 132Section 153CSection 68

necessary satisfaction u/s 153C of the Act was recorded on 29-09-2021 by the Learned AO of the assessee on receipt of a satisfaction note dated 25- 09-2021 from the AO of Shri Rajiv Saxena. Thereafter, notices u/s 153C r.w.s. 153A of the Act were issued ... Hence, the date of search qua the assessee herein would be the date of recording of satisfaction note by the Learned AO of the assessee which is 29-09-2021 which falls in Assessment Year 2022-23. Hence applying the ratio decidendi of Hon'ble Delhi High Court referred supra

DCIT, Central Circle 1, New Delhi vs. Udai Shanker Awasthi, New Delhi

ITA 5345/DEL/2025[2015-16]Status: DisposedITAT Delhi06 Feb 2026AY 2015-16

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Vinod Kumar Bindal, CAFor Respondent: Ms. Pooja Swaroop, CIT (DR)
Section 132Section 153CSection 68

necessary satisfaction u/s 153C of the Act was recorded on 29-09-2021 by the Learned AO of the assessee on receipt of a satisfaction note dated 25- 09-2021 from the AO of Shri Rajiv Saxena. Thereafter, notices u/s 153C r.w.s. 153A of the Act were issued ... Hence, the date of search qua the assessee herein would be the date of recording of satisfaction note by the Learned AO of the assessee which is 29-09-2021 which falls in Assessment Year 2022-23. Hence applying the ratio decidendi of Hon'ble Delhi High Court referred supra

DCIT, Central Circle 1, New Delhi vs. Udai Shankar Awasthi, New Delhi

ITA 5344/DEL/2025[2014-15]Status: DisposedITAT Delhi06 Feb 2026AY 2014-15

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Revenue byFor Respondent: Date of Hearing
Section 132Section 153CSection 68

necessary satisfaction u/s 153C of the Act was recorded on 29-09-2021 by the Learned AO of the assessee on receipt of a satisfaction note dated 25- 09-2021 from the AO of Shri Rajiv Saxena. Thereafter, notices u/s 153C r.w.s. 153A of the Act were issued ... Hence, the date of search qua the assessee herein would be the date of recording of satisfaction note by the Learned AO of the assessee which is 29-09-2021 which falls in Assessment Year 2022-23. Hence applying the ratio decidendi of Hon'ble Delhi High Court referred supra

DCIT, Central Circle 1, New Delhi vs. Udai Shankar Awasthi, New Delhi

ITA 5343/DEL/2025[2013-14]Status: DisposedITAT Delhi06 Feb 2026AY 2013-14

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Vinod Kumar Bindal, CAFor Respondent: Ms. Pooja Swaroop, CIT (DR)
Section 132Section 153CSection 68

necessary satisfaction u/s 153C of the Act was recorded on 29-09-2021 by the Learned AO of the assessee on receipt of a satisfaction note dated 25- 09-2021 from the AO of Shri Rajiv Saxena. Thereafter, notices u/s 153C r.w.s. 153A of the Act were issued ... Hence, the date of search qua the assessee herein would be the date of recording of satisfaction note by the Learned AO of the assessee which is 29-09-2021 which falls in Assessment Year 2022-23. Hence applying the ratio decidendi of Hon'ble Delhi High Court referred supra

DCIT Central Circle-1, New Delhi vs. Udai Shanker Awasthi, New Delhi

ITA 4691/DEL/2025[2012-13]Status: DisposedITAT Delhi06 Feb 2026AY 2012-13

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Vinod Kumar Bindal, CA Ms. Rinky Sharma, ITP Shri Anmol Jha, AdvFor Respondent: Ms. Pooja Swaroop, CIT (DR)
Section 1Section 132Section 153CSection 68

necessary satisfaction u/s 153C of the Act was recorded on 29-09-2021 by the Learned AO of the assessee on receipt of a satisfaction note dated 25- 09-2021 from the AO of Shri Rajiv Saxena. Thereafter, notices u/s 153C r.w.s. 153A of the Act were issued ... Hence, the date of search qua the assessee herein would be the date of recording of satisfaction note by the Learned AO of the assessee which is 29-09-2021 which falls in Assessment Year 2022-23. Hence applying the ratio decidendi of Hon'ble Delhi High Court referred supra

Deputy Commissioner of Income Tax, Delhi vs. Udai Shanker Awasthi, Delhi

ITA 4649/DEL/2025[2011-12]Status: DisposedITAT Delhi06 Feb 2026AY 2011-12

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Vinod Kumar Bindal, CAFor Respondent: Ms. Pooja Swaroop, CIT (DR)
Section 132Section 153CSection 68

necessary satisfaction u/s 153C of the Act was recorded on 29-09-2021 by the Learned AO of the assessee on receipt of a satisfaction note dated 25- 09-2021 from the AO of Shri Rajiv Saxena. Thereafter, notices u/s 153C r.w.s. 153A of the Act were issued ... Hence, the date of search qua the assessee herein would be the date of recording of satisfaction note by the Learned AO of the assessee which is 29-09-2021 which falls in Assessment Year 2022-23. Hence applying the ratio decidendi of Hon'ble Delhi High Court referred supra

Meghna Banga, Delhi vs. DCIT Central Circle-7, Delhi

In the result, the appeal of the assessee is partly allowed

ITA 3936/DEL/2025[2017-2018]Status: DisposedITAT Delhi06 Feb 2026AY 2017-2018

Bench: Shri Mahavir Singh & Shri Krinwant Sahay[Assessment Year: 2017-18]

Section 132Section 142Section 153Section 153CSection 153DSection 250Section 292CSection 65Section 69A

order in haste without application of mind; 3. That impugned order passed u/s 250 by cita, upholding the validity of action u/s 153C and satisfaction note in dismissing jurisdictional ground of appellant of absence of mandatory certificate u/s 65-B(4) of the Indian Evidence Act for admissibility of sole

Raghav Lekhi, C/O B.K Kapur and Company vs. Assessing Officer, New Delhi

In the result, appeal of the assessee is allowed

ITA 3930/DEL/2025[2013-14]Status: DisposedITAT Delhi06 Feb 2026AY 2013-14

Bench: Shri Mahavir Singh & Shri Krinwant Sahayasstt. Year : 2013-14

For Appellant: Madhav Kapur, AdvocateFor Respondent: Shri Mahesh Kumar CIT(DR)
Section 132Section 139(1)Section 149Section 153ASection 153C

Subsequently, AO of the searched party, on the basis of certain alleged incriminating documents pertaining to the assessee recorded its own satisfaction vide Satisfaction Note dated 26.10.2022. Thereafter, the AO of the assessee on being satisfied recorded its own satisfaction vide Satisfaction Note dated 10.11.2022. During the assessment proceedings notice ... Subsequently, AO of the searched party, on the basis of certain alleged incriminating documents pertaining to the assessee recorded its own satisfaction vide Satisfaction Note dated 26.10.2022. Thereafter, the AO of the assessee on being satisfied recorded its own satisfaction vide Satisfaction Note dated 10.11.2022. During the assessment proceedings notice

Kuldeep Saluja, Delhi vs. DCIT, Central Circle-6, New Delhi

ITA 2460/DEL/2025[2015-16]Status: DisposedITAT Delhi06 Feb 2026AY 2015-16

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 132(4)Section 139Section 142(1)Section 143(2)Section 143(3)Section 153CSection 153DSection 250Section 68

list of beneficiaries and their transactions of accommodation entries taken from Shell companies, transaction pertaining to assessee were also found. Based on such information, satisfaction note, by the AO of the searched person was recorded on 24.03.2021 and seized material was handed over to the AO of assessee. Thereafter, notice ... material available on record. The claim of the assessee is that AO the persons searched and of the assessee are common and the "Satisfaction Note” recorded in the case of persons searched is reproduced at page 3 of the assessment order wherein the AO referred certain documents and the Excel

Vinay Homes Pvt Ltd, Delhi vs. DCIT, Central Circle-6, New Delhi

ITA 2459/DEL/2025[2016-17]Status: DisposedITAT Delhi06 Feb 2026AY 2016-17

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 132(4)Section 139Section 142(1)Section 143(2)Section 153CSection 153DSection 250Section 68Section 69C

accommodation entries taken from Shell companies, transaction pertaining to assessee were also found. Accordingly, as per provisions of section 153C of the Act, satisfaction note, by the AO of the searched person was recorded on 24.03.2021 and seized material was handed over to the AO of assessee company. Thereafter, notice ... Heard the contentions of both the parties and perused the material available on record. It was the claim of the assessee that the "Satisfaction Note” recorded in the case of persons searched as reproduced at page 3 of the assessment order referred certain documents and the Excel Sheet however, nowhere

Kavita Gupta, East Delhi vs. Deputy Commissioner of Income Tax, Circle-31, Jhandewalan Extension

In the result, the appeal of the assessee is allowed

ITA 1643/DEL/2025[2020-2021]Status: DisposedITAT Delhi06 Feb 2026AY 2020-2021

Bench: Shri Mahavir Singh & Shri Krinwant Sahay[Assessment Year: 2020-21]

Section 115BSection 153CSection 69

another person. (b) It "belongs to" / "pertains to"/ "relates to" the assessee depending upon the date of search. (c) The A.O. must record a satisfaction note, indicating why he believes the documents belongs to the assessee (d) The A.O. must demonstrate nexus between the seized material and the assessee ... jurisdiction and no document indicating ownership, investment, bank or cash trail of flat allotment is on record pertaining to the Appellant in question and satisfaction note also does not refer to any such belonging documents, hence initiation of proceeding U/s.153C of the Act in the instance case

Asha Gupta, New Delhi vs. DCIT Central Circle 30, New Delhi

In the result, the appeal of the assessee is allowed

ITA 2069/DEL/2024[2021-22]Status: DisposedITAT Delhi06 Feb 2026AY 2021-22

Bench: Shri Mahavir Singh & Shri Manish Agarwal

Section 143(2)Section 143(3)Section 153CSection 153DSection 250Section 69A

natural justice.” 5. In support of the Ground of appeal Nos.1 to 3, Ld.AR for the assessee submits that in the present case, satisfaction note was recorded by the AO of the assessee on 24.05.2022 and thus the search year should be AY 203-24 and accordingly, the assessment

Brijesh Kumar Verma, New Delhi vs. DCIT, Central Circle-7, New Delhi

ITA 402/DEL/2023[2017-18]Status: DisposedITAT Delhi06 Feb 2026AY 2017-18

Bench: Shri Mahavir Singh & Shri Manish Agarwal

Section 132(1)Section 139(1)Section 153CSection 69A

liable to be quashed. That proceedings-initiated u/s 153C of the Act are otherwise also illegal as there was no credible Satisfaction Note of the AO of the Person Searched which give jurisdiction to the AO of the Appellant for initiating the proceedings u/s 153C of the Act. 4. Without