Inordinate Delay in Satisfaction Note Invalidates Section 153C Notice: Gujarat HC

Parag Rameshbhai Gathani Vs ITO (Gujarat High Court) The Gujarat High Court addressed writ petitions challenging notices issued under Section 153C of the Income Tax Act, 1961 (“the Act”) for Assessment Year 2017–18. The petitioner, through the present petition under Article 226 of the Constitution, sought to quash the notice dated 09.02.2024 issued by the Assessing Officer (AO) under Section 153C, calling upon him to furnish a return of income. The notice was based on satisfaction notes recorded by the AO of the petitioner on 14.07.2023 and the AO of the searched person, Suresh R. Thakka...