Section 153C treats the recording of satisfaction, or receipt of...

Section 153C treats the recording of satisfaction, or receipt of seized records by the Assessing Officer of a non-searched person, as that person's deemed search date. Where that event occurs after 1 April 2021, proceedings under section 153C(3) are unavailable and reassessment under section 147 is the applicable route. A consolidated satisfaction note must also identify assessee-specific adverse material and explain its nexus to income alleged to have escaped assessment; generic references to digital devices or electronic evidence do not satisfy this requirement.