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of <h1>Loose sheets no basis for s.153C; separate yearly satisfaction notes mandatory, consolidated notes invalidate entire assessments</h1> SC dismissed the Revenue's SLP, affirming the Karnataka HC's decision that notices issued under s.153C based on loose sheets and diaries were void and ... Validity of proceedings u/s 153C - whether the assessee should be treated as a “Searched Person” or “Other Person”? - Whether ‘Loose Sheets’ and ‘Diary’ have any evidentiary value? - HELD THAT:- We are not inclined to interfere with the impugned judgment and order passed by the High Court of Karnataka at Bengaluru in Writ Appeal [2024 (2) TMI 116 - KARNATAKA HIGH COURT] held notices issued u/s 153C of the Act, based on the loose sheets/diaries are contrary to law, which require to be set aside in these writ appeals, as the same are void and illegal. As satisfaction note is required to be recorded u/s 153C for each Assessment Year and in the impugned proceedings, a consolidated satisfaction note has been recorded for different Assessment Years, which also vitiates the entire assessment proceedings. In view of all these findings, it is said that the appeals do not have any substance for seeking intervention as sought for by the appellant / Revenue. As per the Panchanama provided herein, it is deemed appropriate to conclude that the notice provided u/s 153C is bad in law. Special Leave Petition is dismissed. The Supreme Court dismissed the Special Leave Petition and declined to interfere with the judgment of the High Court of Karnataka in Writ Appeal No. 831/2022 (T-IT) dated 22-01-2024. Delay was condoned, and pending applications were disposed of.
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