Section 153C satisfaction note must be recorded immediately after search assessment; long delay bars proceedings.

Proceedings under Section 153C require a satisfaction note as a sine qua non, and where it is recorded only after completion of the searched person's assessment, it must be prepared immediately thereafter. "Immediately" requires temporal proximity, not merely action within a reasonable period, and the CBDT circular applies that principle to Section 153C. On these facts, the searched persons' assessments ended in September 2022, but satisfaction was recorded only in July 2024, creating a delay of about 21 months. That delay was not curable by a later satisfaction note from the other person's Assessing Officer, so the Section 153C notices and consequential orders were barred by limitation and unsustainable.

---

---

Issues: Whether the proceedings initiated under Section 153C were barred by limitation because the satisfaction note was recorded only after a long delay following completion of the searched persons' assessments.

Analysis: The governing principle drawn from the Supreme Court's exposition is that a satisfaction note is a sine qua non for proceedings against the other person and, where it is recorded after completion of the searched person's assessment, it must be prepared immediately thereafter. The term "immediately" was construed to require proximity in time and not merely action within a reasonable period. The CBDT circular expressly extended that principle to proceedings under Section 153C. On the facts, the searched persons' assessments were completed in September 2022, whereas the satisfaction note was recorded only in July 2024, resulting in a delay of about 21 months. Such delay could not be treated as immediate, and the later recording of satisfaction by the petitioner's Assessing Officer could not cure the delay attributable to the searched person's Assessing Officer.

Conclusion: The proceedings under Section 153C were barred by limitation and the impugned notices and consequential orders were unsustainable.

---