https://www.taxtmi.com/caselaws?id=781850 Recording a satisfaction note is a mandatory jurisdictional precondition for initiating assessment proceedings against a person other than the searched person under Section 153C. The note may be recorded at the initiation of, during, or immediately after completion of the searched person's assessment. Recording it 22 months after that assessment was not immediate and undermined the requirement for expeditious and certain search assessments. Neither the pandemic nor implementation of the faceless assessment scheme justified the delay, as the searched person's assessment was completed during the pandemic and Sections 153A and 153C proceedings were outside that scheme. The Section 153C notices were therefore invalid and quashed. en-us Tue, 18 Nov 2025 00:00:00 +0530 Tue, 28 Jul 2026 10:38:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781850 Recording a satisfaction note is a mandatory jurisdictional precondition for initiating assessment proceedings against a person other than the searched person under Section 153C. The note may be recorded at the initiation of, during, or immediately after completion of the searched person's assessment. Recording it 22 months after that assessment was not immediate and undermined the requirement for expeditious and certain search assessments. Neither the pandemic nor implementation of the faceless assessment scheme justified the delay, as the searched person's assessment was completed during the pandemic and Sections 153A and 153C proceedings were outside that scheme. The Section 153C notices were therefore invalid and quashed. Case-Laws Income Tax Tue, 18 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781850