Rajib Mukhopadhyay v. DCIT: Satisfaction notes issued ten months after completing assessment of the searched person are time-barred and invalid under Section 153C.

12. Rajib Mukhopadhyay V/s. DCIT, Circle - 42(3)(1)

[WP NO. 274 OF 2026 & 936 OF 2026, dated 17/08/2026, (Bom)(HC)]

[Assessment Years 2019-20 and 2020-21]

Section 153C: Satisfaction Note - time barred - as the same was not issued “immediately” and was issued ten months after the assessment proceedings of the searched person were completed.

The Petitioner submitted that the Satisfaction Notes dated 3rd August 2023 and 10th August 2023 were not recorded “immediately”, as stipulated by the Hon’ble Supreme Court in the case of Commissioner of Income-tax-III vs. Calcutta Knitwears [(2014) 362 ITR 673 (SC)]. Therefore, the notices issued under section 153C of the Act be quashed and set aside. The Petitioner relied on the decision dated 24th June 2026, passed in the Petitioner’s case for Assessment Years 2015-16, 2016-17, 2017-18, 2018-19, and 2021-22.

The Hon’ble court observed that for the aforementioned Assessment, this Court had already taken a view in the Petitioner’s own case that the notice dated 10th August 2023 issued under section 153C of the Act was time barred as the same was not issued “immediately” as per law laid down by the Hon’ble Supreme Court