A consolidated satisfaction note recorded for multiple assessment years, which fails to bifurcate amounts or identify year-specific incriminating material, is invalid and does not confer jurisdiction under Section 153C of the Income Tax Act, 1961, as the statute requires year-specific formation of opinion.

ORDER

PER YOGESH KUMAR, U.S. JM:

The captioned Appeals are filed by the Assessee against the orders of Ld. Commissioner of Income Tax (Appeals)(‘Ld. CIT(A) for short), New Delhi-23 dated23/12/2025 pertaining to the Assessment Years 2017-18, 2018-19, 2019-20 and 2020-21 respectively.

2. Brief facts of the case are that, a search and seizure action u/s 132 of the Income Tax Act, 1961 was carried out in the Sanjay Jain and Pankaj Jain Group of cases on 30.06.2019 & 03.07.2019. During search, residence of the assessee Sh. Chander Shekar Jha addressed at A-227, Defence Colony, Delhi was covered and a number of documents were found and seized which inter alia includes unsecured cash loan and undisclosed cash. Based on the evidence gathered during the search, AO of the searched person as per section 153A of the Act recorded satisfaction note and forwarded the same to the AO of assessee. Further, a satisfaction note was recorded by the AO of the any other person i.e., the assessee as per the provisions of the Section 153C of the Act. Assessment orders have been passed on 31/03/2024 against the Assessee for Assessment Year 2017-19, 2018-19, 2019-20 and 2020-21 under Section 153C of the Income Tax Act, 1961 ('Act' for short) by making certain additions. Aggrieved by the assessment orders dated 31/03/2024, Assessee preferred captioned Appeals before the Ld. CIT(A). The Ld. CIT(A) vide orders dated 23/12/2025, dismissed the Appeals of the Assessee. As against the orders of the Ld. CIT(A) dated 23/12/2025, Assessee preferred the captioned Appeals on the grounds mentioned above. Though the Assessee has

3. Though the Assessee has raised several grounds of Appeals, we have heard only on GroundNo. 4 of the Assessee. The Ld. Assessee's Representative contended that initiation of assessment proceedings u/s 153C of the Act for four Assessment Year i.e. A.Y2017-18 to 2020-21 by recording consolidated satisfaction note for all Assessment Years, which is bad in law and liable to be quashed as per the law laid down by Hon'ble Supreme Court, various Hon'ble High Courts and also the ratio laid down by the Tribunal. The Ld. Counsel has also relied on the following judicial precedents:

i Judgment of Hon'ble High Court of Karnataka in the case of Deputy Commissioner of Income Tax Vs. Sunil Kumar Sharma reported in [2024] 159 taxmann.com 179 (H.C-Karnataka).

ii. Judgment of Hon'ble High Court of Delhi Shaksham Commodities Ltd. Vs. ITO reported in [2024] 161 taxmann.com 485 (Delhi) [DoD:11/12/2025].

4. Per contra, the Ld. Department's Representative apart from making oral argument, submitted a written submission and sought for dismissal of the Ground No. 4 in all the appeals. The written submission filed by the Ld. Departmental Representative is reproduced as under: -

“It is humbly submitted that during the course of hearing, the assessee pressed the technical ground that satisfaction recorded u/s 153C is defective because of being consolidated satisfaction note. In this regard, my humble submission for kind consideration are as under:

Section 153C starts with non-obstante clause relating to normal assessment procedure. Bare reading of Section 153C makes it clear that it has 02 limbs:

AO has to make a satisfaction to the effect that the seized material either pertains to or contain information of the other person (not covered under the search)- the assessee in the instant case.

The seized material has a bearing with the escaped income. In other words, there should be a direct relationship between the escaped income and the tell-tale seized material/documents.

For better appreciation, the relevant portion of the provision of Section 153C is rep