A search u/s 132 was conducted on 23.01.2018 at the premises of Shri Pravin Jivrajbhai Tarpara, during which loose papers said to pertain to the assessee were seized. The searched person’s own assessment u/s 153A was completed on 07.06.2021, but the satisfaction note for assuming jurisdiction over the assessee was recorded only on 23.11.2022 — some 17 months later. Assessments u/s 153C r.w.s. 144 followed on 30.12.2022 for AYs 2015-16 to 2018-19, and both the assessment and the CIT(A) order were ex-parte. The appeals were filed 131 days late; applying s. 253(5) and Mst. Katiji, the Tribunal condoned the delay.

On merits, the argument rested on CIT v. Calcutta Knitwears (SC) and CBDT Circular No. 24/2015, which permit the satisfaction note to be recorded at only three points: at initiation of proceedings against the searched person, during those proceedings, or immediately after their completion. Stages one and two were never used, and stage three opened in June 2021 with nothing on record explaining the 17-month silence that followed. COVID could not account for it, since the searched person’s assessment was itself framed during the pandemic. The jurisdictional High Court in Parag Rameshbhai Gathani [2025] 180 taxmann.com 662 (Guj) had quashed s. 153C notices on a 22-month delay in materially identical circumstances, rejecting both pandemic and Faceless Scheme workload as afterthoughts.

The Tribunal found the case squarely covered, noting that the Revenue’s SLP against Gathani had been dismissed by the Supreme Court on 27.07.2026. Holding that a satisfaction note recorded after such inordinate delay is contrary to the procedure prescribed for assumption of jurisdiction u/s 153C, it quashed all four assessment orders. The remaining grounds were left unadjudicated as academic. The ruling treats the timing of the satisfaction note as jurisdictional rather than procedural — a defect fatal at the threshold, irrespective of the strength of the seized material or the ex-parte history below.