https://www.taxtmi.com/caselaws?id=467137 The Fourth Proviso to Section 153A requires recorded satisfaction that escaped income for the relevant assessment years amounts to or is likely to amount to the prescribed threshold before extended ten-year search assessment proceedings can be initiated. A satisfaction note must reflect an assessment of the seized material and reasons supporting that conclusion; a provisional opinion cannot rest on conjecture. Because the satisfaction note did not indicate that escaped income cumulatively or in aggregate met or was likely to meet the threshold, the Section 153C notices for the specified assessment years were quashed. The assessing officer may reconsider the matter only on recorded reasons and in accordance with law. en-us Fri, 24 May 2024 00:00:00 +0530 Fri, 06 Mar 2026 20:54:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467137 The Fourth Proviso to Section 153A requires recorded satisfaction that escaped income for the relevant assessment years amounts to or is likely to amount to the prescribed threshold before extended ten-year search assessment proceedings can be initiated. A satisfaction note must reflect an assessment of the seized material and reasons supporting that conclusion; a provisional opinion cannot rest on conjecture. Because the satisfaction note did not indicate that escaped income cumulatively or in aggregate met or was likely to meet the threshold, the Section 153C notices for the specified assessment years were quashed. The assessing officer may reconsider the matter only on recorded reasons and in accordance with law. Case-Laws Income Tax Fri, 24 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467137