The Assessee, approaching Hon’ble High Court contended that the proceedings under S. 153C were invalid because there was no incriminating material for the impugned years and the satisfaction notes did not explain how any seized material had a bearing on the determination of total income for those years.

The Hon’ble Delhi High Court quashed the S. 153C proceedings/notice on the grounds that, absent incriminating material and proper satisfaction demonstrating bearing on total income for the year, Sec. 153C could not be sustained.

The Revenue challenged the High Court’s quashing of the 153C proceedings by filing an SLP before the Supreme Court (i.e., Revenue sought to sustain the 153C action set aside by the High Court), albeit with substantial delay and did not overcome the High Court’s reasoning on the need for incriminating material and proper satisfaction for each year.

The Hon’ble Supreme Court  dismissed the SLP as time‑barred and on merits; the Supreme Court refused to interfere, effectively affirming the High Court’s quashing of the S. 153C proceedings. (AY. 2015-16)