Single Satisfaction Note under Section 153C for Multiple Years is invalid: Karnataka HC

DCIT Vs Sunil Kumar Sharma (Karnataka High Court) The Karnataka High Court upheld a lower court’s decision, ruling that a single “satisfaction note” used by the Deputy Commissioner of Income Tax (DCIT) to assess income for multiple assessment years under Section 153C of the Income Tax Act is invalid. The court dismissed appeals filed by the DCIT against Sunil Kumar Sharma, reinforcing that separate satisfaction notes are mandatory for each assessment year. The core argument presented by Sharma’s counsel, and accepted by the court, was that the consolidated satisfaction ...