Bombay HC Quashed Section 153C Proceedings Due to Delay in Recording Satisfaction Note

Nippon Life India Asset Management Limited Vs DCIT (Bombay High Court) The Court quashed notices issued under Section 153C and related proceedings on the ground of limitation, holding that the satisfaction note was not recorded “immediately” after completion of assessment of the searched persons. The search was conducted in February 2021 and assessments were completed in September 2022, but the satisfaction note was recorded only in July 2024, resulting in a delay of about 21 months. Relying on the Supreme Court ruling in Calcutta Knitwears, the Court emphasized that the requirement of rec...