2025 (5) TMI 1504 - SCH - Income Tax

Validity of notices issued u/s 153C - mandation of recording satisfaction - HC decided Satisfaction Note issued by the jurisdictional Assessing Officer AO of the petitioner does not refer to incriminating material for any of the aforenoted AYs it is ex facie evident that no incriminating material has been found for the said AYs . Jurisdictional AO would have to firstly be satisfied that the material received is likely to have a bearing on or impact the total income of years or years which may form part of the block of six or ten AYs and thereafter proceed to place the assessee on notice under Section 153C. Absent any material that may either cast a doubt on the estimation of total income for a particular year or years the AO would not be justified in invoking its powers conferred by Section 153C. Assessee appeal allowed. HELD THAT - Having heard the learned counsel appearing for the petitioners and having gone through the materials on record we see no reason to interfere with the impugned order passed by the High Court. The Special Leave Petitions are accordingly dismissed.

Summary

The Supreme Court, with Justices J. B. Pardiwala and R. Mahadevan presiding, after hearing counsel and reviewing the record, "see[s] no reason to interfere with the impugned order passed by the High Court." The Court accordingly "dismiss[ed] the Special Leave Petitions," condoned delay, and disposed of pending applications.