Shyamlal Rupchand Parwani v. ACIT (2024) 297 Taxman 581 / 337 CTR 850 (Guj.)(HC)

S. 153C : Assessment-Income of any other person-Search and seizure-Satisfaction note-Served satisfaction note subsequent to notice under section 143(2)-Writ petition is dismissed.[S. 132 142(1), Art. 226]

In response to notice under section 153C dt. 9-6-2022 the Assessee had filed return. Notice issued under section 142(1) dated 11-12-2023. Assessee filed writ petition on the ground that no satisfaction note was provided along with notice under section 153C. Dismissing the petition the Court held that satisfaction note of Assessing Officer had been served upon assessee, subsequent to notice under section 142(1) dated 11-12-2023 hence the assessee should have raised all possible objections before Assessing Officer during course of assessment proceedings instead of filing writ petition.  Circular No. 24 of 2015, dated 31-12-2015. (AY. 2014-15)