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HC affirmed that recording a satisfaction note is mandatory before initiating proceedings under Section 153C, even when the Assessing Officer for both searched and other persons is identical. The court relied on CBDT Circular No.24/2015, which mandates recording separate satisfaction notes following Apex Court guidelines. The absence of a distinct satisfaction note pertaining to the other person invalidates proceedings under Section 153C. HC upheld the ITAT's order, finding it consistent with established legal principles. The revenue's appeal was dismissed, confirming CIT(Appeals) and ITAT's previous rulings that emphasized the fundamental requirement of a properly documented satisfaction note as a jurisdictional prerequisite for Section 153C actions.
HC affirmed that recording a satisfaction note is mandatory before initiating proceedings under Section 153C, even when the Assessing Officer for both searched and other persons is identical. The court relied on CBDT Circular No.24/2015, which mandates recording separate satisfaction notes following Apex Court guidelines. The absence of a distinct satisfaction note pertaining to the other person invalidates proceedings under Section 153C. HC upheld the ITAT's order, finding it consistent with established legal principles. The revenue's appeal was dismissed, confirming CIT(Appeals) and ITAT's previous rulings that emphasized the fundamental requirement of a properly documented satisfaction note as a jurisdictional prerequisite for Section 153C actions.
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