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Section 153C proceedings against a person other than the searched person require a satisfaction note as a precondition. Where the searched person's assessment has concluded, the satisfaction note must be recorded immediately thereafter; a delay exceeding four years does not meet that requirement. Proceedings initiated for Assessment Year 2017-18 on the basis of such delayed recording were invalidated, and the related notice, consequential order and demand notice were quashed.
Section 153C proceedings against a person other than the searched person require a satisfaction note as a precondition. Where the searched person's assessment has concluded, the satisfaction note must be recorded immediately thereafter; a delay exceeding four years does not meet that requirement. Proceedings initiated for Assessment Year 2017-18 on the basis of such delayed recording were invalidated, and the related notice, consequential order and demand notice were quashed.
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