2025 (7) TMI 910 - SCH - Income Tax

Validity of notices issued u/s 153C - mandation of recording satisfaction HC 2024 (5) TMI 1571 - DELHI HIGH COURT 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 u/s 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 - Petitioners fairly submitted that against a common impugned judgment passed by the High Court deciding a batch of petitions this Court 2025 (5) TMI 1504 - SC ORDER along with other connected matters. The present Special Leave Petition is accordingly dismissed.

Summary

The Supreme Court, in a partial bench comprising Hon'ble Mr. Justice Rajesh Bindal and Hon'ble Mr. Justice R. Mahadevan, heard the Special Leave Petition (SLP) against a common impugned judgment of the High Court. The Court "condoned delay" but noted that a similar batch of petitions had already been dismissed by this Court's order dated 16.05.2025 (SLP(C) Diary No. 18596 of 2025). Consequently, the present Special Leave Petition was "dismissed," and all pending applications were disposed of.