In Brief
M/s Super Malls Private Limited challenged assessments made under Section 153C of the Income Tax Act following a search of its director's residence. The Court examined whether the Assessing Officer properly complied with mandatory requirements to record a satisfaction note that seized documents belonged to the assessee rather than the searched person. The Court held that Section 153C requirements are mandatory but recognized that when the same officer handles both the searched person and the assessee, a single satisfaction note suffices if it explicitly states the seized documents belong to the other person. Finding the satisfaction note clearly expressed such satisfaction, the Court dismissed the appeals and remitted matters to the tribunal for merit-based decision."
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