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2025 Supreme(Online)(Mad) 30537

IN THE HIGH COURT OF JUDICATURE AT MADRAS
R.SURESH KUMAR, J
Revenue – Appellant
Versus
Assessee – Respondent


Advocates:
For the Appellants/Petitioners: Mr.Karthik Ranganathan
For the Respondents: Dr.S.Muralidhar, Mr.G.Baskar

Table of Content
1. factual background of the tax case appeals. (Para 2 , 3)
2. parties' arguments regarding assessment orders. (Para 4 , 5 , 6 , 8 , 9 , 10)
3. court's observations on the necessity of satisfaction notes. (Para 12 , 13 , 14 , 15)
4. legal principles regarding recording satisfaction notes. (Para 16 , 18 , 19 , 20)
5. court's analysis of the applicability of previous judgments. (Para 22 , 23 , 24)
6. court's reasoning on the validity of the assessment orders. (Para 25 , 26 , 27 , 28)
7. court's conclusion on the necessity of separate satisfaction notes. (Para 29 , 30 , 31)
8. final conclusion on the appeal's dismissal. (Para 32 , 33 , 34)

R.SURESH KUMAR, J.

Since the issue raised in all these Tax Case Appeals is one and the same against the same assessee, all these Appeals were heard together and are disposed by this common order.

2. The necessary facts which are required to be noticed for the disposal of these Appeals are as follows :

(i) The Assessee was engaged in the business of Systems and Software Services. On 12.08.2004, the search was conducted at the premises of the Chairman of the Assessee Company under Section 132 of the Income Tax Act 1961, in short “the Act”.

(ii) Pu

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