Case LawsIncome Tax
Show AI Summary
Search and seizure procedural compliance: satisfaction note requirement under section 153C governs validity of assessments.
Assessments against persons other than the searched individual require a recorded satisfaction by the assessing officer that seized assets or documents belong to that other person; absence of a satisfaction note in the searched person's file invalidates consequential assessments under the search-derived assessment provisions. Determination of the applicable assessment years hinges on whether the assessment period is tied to the date of search, the date satisfaction is recorded, or the date seized material is received, requiring harmonious construction to align enforcement with taxpayer protections.