Writ petition challenges section 153C notices as time-barred over delayed satisfaction note

5-Second Takeaway

The court held that the challenge to the section 153C notices turns on whether the searched person’s satisfaction note was recorded and forwarded within the required time, and it treated the limitation issue as a pure question of law. It directed the writ petition to be listed for final hearing, following Calcutta Knitwears on the governing requirement.

The petition concerns notices issued under section 153C after search proceedings in the case of the searched person, Ramkumar Soni. The petitioner contends that the searched person’s assessment should have ended by 31 December 2018, but the satisfaction note was prepared only on 1 March 2022 and then forwarded to the petitioner’s assessing officer.

On that basis, the petitioner argues that the section 153C notices are time-barred because the note was not recorded and transmitted immediately after the searched person’s assessment was completed. The Revenue disputes the limitation challenge and maintains that the satisfaction note was issued and forwarded in compliance with the statutory scheme.

The court noted that the controversy is purely one of law and that there is no factual dispute requiring evidence. It also recorded the governing principle from CIT v. Calcutta Knitwears on the timing of the satisfaction note.

The writ petition has been directed to be heard finally on 28 July 2026 at 3:00 p.m., with the limitation issue left for adjudication on the merits.