Section 153C Notices Quashed as Satisfaction Note Was Recorded Nearly 10 Months Late

Rajib Mukhopadhyay Vs DCIT (Bombay High Court) Core Issue: The principal issue before the Bombay High Court was whether proceedings initiated under section 153C were valid where the satisfaction note of the Assessing Officer of the searched person was recorded nearly ten months after completion of the assessment of the searched person. The Court examined whether the requirement laid down by the Supreme Court in Calcutta Knitwears that the satisfaction note be recorded “immediately” after completion of the searched person’s assessment constitutes a mandatory jurisdicti...