South Coast Spices Exports (P.) Ltd. v. PCIT (2024) 296 Taxman 184 (Ker.)(HC)

S. 153C : Assessment-Income of any other person-Search and seizure-Satisfaction note without document identification no (DIN)-When satisfaction notes were provided to assessee, said communication bore DIN-Notice and assessment order is valid.[Art. 226]

Assessing Officer after recording satisfaction, issued notice under section 153C. Thereafter, assessment orders were passed. On writ the  assessee challenged the  orders on ground that satisfaction notes supplied to assessee did not bear DIN. Dismissing yhe petition the Court held that satisfaction note was document prepared by Assessing Officer which was kept in file and unless demanded by assessee it was not required to be provided to assessee. Since when satisfaction notes were provided to assessee, said communication bore DIN hence  notices and assessment orders were not without jurisdiction. Circular No. 19/2019, dated 14-8-2019 (AY. 2015-16 to 2020-21)