Validity of assessment under section 153C challenged over missing DIN in satisfaction notes; court upholds assessments as valid.

Assessment under section 153C was challenged on grounds that the notice and satisfaction note did not specify the recording authority's DIN and thus purportedly lacked jurisdiction. The High Court found the Assessing Authority had examined seized documents and recorded satisfaction, and that the satisfaction notes were placed on file and furnished to the petitioner on demand. The Court held a DIN is not a mandatory element of a satisfaction note, and absence of a DIN does not vitiate jurisdiction. Consequence: the notices and assessment orders under section 153C were held valid on the recorded satisfaction reasoning.

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Issues involved: Impugning notices under Section 153C of the Income Tax Act for multiple Assessment Years, jurisdiction of Assessment Orders, satisfaction note requirement, validity of proceedings, relevance of satisfaction notes bearing DIN number.

Jurisdiction of Assessment Orders: The petitioner challenged Assessment Orders for the Assessment Years 2015-16 to 2021-22 issued under Section 153C of the IT Act, claiming that they were without jurisdiction and against the law. The petitioner contended that the Assessing Officer must record a satisfaction note before issuing notices under Section 153C to a person other than the searched person. The notices issued did not mention the satisfaction note recorded by the Assessing Officer. The petitioner argued that the proceedings were invalid due to the absence of the DIN number on the satisfaction notes provided. The petitioner approached the Court under Article 226 of the Constitution of India without going to the Appellate Authority.

Validity of Proceedings: A search operation revealed incriminating documents indicating unaccounted income and diversion of business funds to evade taxation. The Assessing Officer issued notices under Section 153C to the petitioner for the Assessment Years 2015-16 to 2020-21 based on evidence gathered during the search. The Assessment Orders were finalized after following the procedure under Section 153C. The satisfaction notes provided to the petitioner were found to have been examined by the Assessing Authority, satisfying the requirement for issuing notices under Section 153C.

Relevance of Satisfaction Notes: The petitioner demanded the satisfaction note, which was provided by the Assistant Commissioner of Income Tax. The petitioner argued that the absence of the DIN number on the satisfaction notes rendered the proceedings invalid. However, the Court found that the satisfaction note does not need to bear the DIN number. The judgment cited by the petitioner was deemed inapplicable to the present case as the facts were distinguishable. The Court concluded that the impugned notices and assessment orders were not without jurisdiction, and the writ petition was dismissed, allowing the petitioner to appeal against the assessment orders if desired.

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