On the facts, assessment proceedings against the searched person were completed in September 2022; satisfaction notes and transmissions occurred in mid‑2023 and notices under section 153C were issued on March 30, 2024. The Court found no delay and dismissed challenges; the SLP was dismissed.(AY. 2015‑16 to 2017‑18)
Bhupinder Singh Kapur v. ITO (2025) 474 ITR 331 (SC) Editorial: Bhupinder Singh Kapur v. ITO (2025) 474 ITR 326 (P&H) (HC)
S.153C: Assessment-Income of any other person-Search-Recording of satisfaction-Limitation-Preparation of satisfaction note not a mechanical process-No delay; objections on limitation not raised before AO-SLP dismissed. [S. 132(1), 153A, 153D, Art.136]