Assessment against the searched person was completed under section 158BC (now section 153A) in September 2022. The AO of the searched person drew a satisfaction note on June 7, 2023 and transmitted documents to the assessee’s AO, who prepared his satisfaction note on October 31, 2023. Notice under section 153C was issued on March 30, 2024. The High Court held there was no delay; the words “immediately after” in Circular No. 24/2015 could not mean within a few days. Preparation of a satisfaction note requires reasoned consideration and is not mechanical. Since the assessee did not raise the objection of limitation beyond six years before the AO, it could not be considered later. No jurisdictional error was found and the writ petition was dismissed.(AY. 2015-16 to 2017-18)
Bhupinder Singh Kapur v. ITO (2025) 474 ITR 326 (P&H)(HC) Editorial: SLP of assessee dismissed, Bhupinder Singh Kapur v. ITO (2025) 474 ITR 331 (SC)
S.153C : Assessment-Income of any other person-Search-Recording of satisfaction-Limitation-Preparation of satisfaction note not a mechanical process-No delay in initiation-Objection on limitation not raised before AO-Writ petition dismissed. [S.132(1), 153A, 153D, Art.226]