https://www.taxtmi.com/caselaws?id=789972 Proceedings under Section 153C require a satisfaction note as a sine qua non, and where it is recorded only after completion of the searched person's assessment, it must be prepared immediately thereafter. "Immediately" requires temporal proximity, not merely action within a reasonable period, and the CBDT circular applies that principle to Section 153C. On these facts, the searched persons' assessments ended in September 2022, but satisfaction was recorded only in July 2024, creating a delay of about 21 months. That delay was not curable by a later satisfaction note from the other person's Assessing Officer, so the Section 153C notices and consequential orders were barred by limitation and unsustainable. en-us Tue, 07 Apr 2026 00:00:00 +0530 Fri, 17 Apr 2026 08:21:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789972 Proceedings under Section 153C require a satisfaction note as a sine qua non, and where it is recorded only after completion of the searched person's assessment, it must be prepared immediately thereafter. "Immediately" requires temporal proximity, not merely action within a reasonable period, and the CBDT circular applies that principle to Section 153C. On these facts, the searched persons' assessments ended in September 2022, but satisfaction was recorded only in July 2024, creating a delay of about 21 months. That delay was not curable by a later satisfaction note from the other person's Assessing Officer, so the Section 153C notices and consequential orders were barred by limitation and unsustainable. Case-Laws Income Tax Tue, 07 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789972