Threshold for search-related notices requires a recorded, reasoned satisfaction of likely escaped income before notices can stand.

The note clarifies that search-related notices issued under Section 153C require a recorded, reasoned satisfaction that the escaped income cumulatively meets the statutory monetary threshold under the Fourth Proviso to Section 153A; provisional opinion or conjecture is insufficient. Because the Satisfaction Note did not record reasons showing escaped income amounts or likelihood to meet the threshold, the subsequent notices were held unsustainable and quashed. The assessing officer may re-examine and reissue notices only after recording a fresh, material-based satisfaction that the monetary threshold is likely met.

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Issues: Whether the notices issued under Section 153C of the Income-tax Act, 1961 dated 29 June 2022 in respect of the specified assessment years are sustainable where the Satisfaction Note dated 22 June 2022 does not demonstrate that escaped income for the relevant assessment years meets or is likely to meet the INR 50 lakhs threshold prescribed by the Fourth Proviso to Section 153A of the Income-tax Act, 1961.

Analysis: The Court applied the legal framework governing issuance of search-related assessment notices, with specific reference to the Fourth Proviso to Section 153A of the Income-tax Act, 1961 which imposes a minimum threshold of INR 50 lakhs (expressed as amounts that "amount to or are likely to amount"). The Court relied on the reasoning in Principal Commissioner of Income Tax Central - 1 v. Ojjus Medicare Pvt. Ltd., holding that while an assessing officer's opinion may be provisional, the satisfaction and reasons must be founded on an assessment of the material and not mere conjecture. The Court further recognised that the threshold requirement is a sine qua non for initiating extended ten-year block proceedings and that the Satisfaction Note must record reasons indicating that escaped income cumulatively or in aggregate meets or is likely to meet the INR 50 lakhs benchmark. Applying these principles to the undisputed fact that the Satisfaction Note was dated 22 June 2022 and showed no such satisfaction, the Court concluded that the impugned notices could not be sustained as issued.

Conclusion: The impugned notices issued under Section 153C of the Income-tax Act, 1961 dated 29 June 2022 insofar as they relate to the specified assessment years are quashed. The assessing officer may, if satisfied for reasons recorded and in accordance with law that the escaped income is likely to exceed INR 50 lakhs, examine the matter afresh and proceed if permissible.

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