Agni Vishnu Ventures Pvt. Ltd. Vs DCIT (Madras High Court)
The batch of writ petitions arose from assessments framed under Section 153C read with Section 143(3) of the Income-tax Act following searches conducted in the Agni group and related premises. The petitioners challenged the notices, assessments and connected proceedings on several grounds, including the validity of the satisfaction notes, alleged procedural irregularities, contradictions regarding the source of seized material, violation of natural justice, and the absence of incriminating material supporting assessments for all years covered by the block period.
In one set of cases, the Revenue relied upon satisfaction notes referring to seized loose sheets, tax consultation advice and electronic data allegedly indicating foreign remittances and investments through overseas entities. The petitioners disputed the factual basis of these conclusions, questioned the reliance on material seized in another search, and argued that the satisfaction notes merely described remittances as “suspicious” without sufficient legal basis. The Revenue maintained that the assessments were validly made, that procedural requirements had been followed, and that the assessments were protective while substantive assessments had been framed in another case. The Court found that many of these objections involved disputed questions of fact better suited for statutory appellate proceedings.
