https://www.taxtmi.com/caselaws?id=787096 A satisfaction note initiating search-triggered assessment proceedings must be recorded immediately after completion of the searched person's assessment; a delay of approximately fifteen months rendered the impugned proceedings time-barred. Separately, such satisfaction notes qualify as communications requiring a Document Identification Number under the applicable CBDT circular, and absence of a DIN invalidates the communication. The combined effect is that a notice issued to commence proceedings based on a delayed or DIN-less satisfaction note is quashed and the consequential proceedings set aside, with both defects independently fatal to the exercise of the power to proceed. en-us Tue, 17 Feb 2026 00:00:00 +0530 Wed, 01 Jul 2026 12:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787096 A satisfaction note initiating search-triggered assessment proceedings must be recorded immediately after completion of the searched person's assessment; a delay of approximately fifteen months rendered the impugned proceedings time-barred. Separately, such satisfaction notes qualify as communications requiring a Document Identification Number under the applicable CBDT circular, and absence of a DIN invalidates the communication. The combined effect is that a notice issued to commence proceedings based on a delayed or DIN-less satisfaction note is quashed and the consequential proceedings set aside, with both defects independently fatal to the exercise of the power to proceed. Case-Laws Income Tax Tue, 17 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787096