Belated satisfaction note under section 153C invalidates jurisdiction where search assessment was already completed.

Section 153C proceedings require a valid satisfaction note recorded within a reasonable time and not after completion of the searched person's assessment beyond the permissible period. The article notes that, where the assessment of the searched person had already been completed and the satisfaction notes in both cases were recorded later, the jurisdictional basis for initiating section 153C action was treated as invalid. On that footing, the reassessment orders were quashed in favour of the assessee.

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Issues: Whether the assumption of jurisdiction under section 153C of the Income-tax Act, 1961 was vitiated because the satisfaction note was recorded after completion of the assessment of the searched person and beyond the permissible period.

Analysis: The assessments arose from a search conducted on 02.01.2020 in the group case. The record showed that the assessment of the searched person had already been completed before the satisfaction notes were recorded, and the satisfaction note in the assessee's case was also recorded subsequently. The Tribunal relied on the settled requirement that satisfaction for section 153C proceedings must be recorded within a reasonable time and, as reflected in the CBDT circular, not beyond the permissible period after completion of assessment of the searched person. Since the satisfaction in both the searched person's case and the assessee's case was recorded belatedly, the jurisdictional foundation for initiating proceedings under section 153C was held to be invalid.

Conclusion: The initiation of proceedings under section 153C was invalid and the reassessment orders were quashed in favour of the assessee.

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