2025 (5) TMI 221 - SCH - Income Tax

Validity of reassessment proceedings - Issue the satisfaction note w/o DIN number to the assessee at the time of issuance of notice for reassessment - As decided by HC 2024 (6) TMI 1462 - GUJARAT HIGH COURT on perusal of the section 148 there is no provision to give a copy of satisfaction note recorded by the AO along with the notice u/s 148. AO has uploaded the satisfaction note which is an internal communication sent along with the proposal which is evident from the communication addressed by the AO to the PCIT which clearly shows the enclosure as a satisfaction note. No interference is called for in the impugned notice issued u/s 148. HELD THAT - We are not inclined to interfere with the impugned judgment passed by the High Court. Hence the Special Leave Petition is dismissed. Pending applications if any shall stand disposed of.

Summary

The Supreme Court, with Hon'ble Justices Pamidighantam Sri Narasimha and Manoj Misra presiding, heard the Special Leave Petition. After considering the submissions of counsel for both parties, the Court stated it was "not inclined to interfere with the impugned judgment passed by the High Court." Consequently, the Special Leave Petition was dismissed, and all pending applications were disposed of.