The Delhi High Court’s 10 February 2025 order in two Section 153C petitions did not quash an income-tax notice or order. It directed the Revenue to produce the relevant record and continued interim protection while the court examined discrepancies concerning the satisfaction notes and the officers involved.
What the Delhi High Court ordered on 10 February 2025
The order concerned W.P.(C) 15923/2023, filed by Sanjeev Agarwal, and W.P.(C) 35/2024, filed by Sudhir Agarwal, before Justices Yashwant Varma and Harish Vaidyanathan Shankar. The court said the issues warranted an explanation, directed the Revenue to produce the relevant record at the next hearing, and continued interim protection. It did not finally decide whether the notice was invalid or quash it. Delhi High Court order, 10 February 2025.
What the order says about the satisfaction notes and notice
According to the respondents’ additional affidavit as recounted in the order, the searched entity’s jurisdictional Assessing Officer drew a satisfaction note on 9 June 2022. It concerned a search of the Alankit Group conducted on 18 October 2019 and documents said to pertain to the writ petitioner; the material was reportedly transmitted to the petitioner’s jurisdictional Assessing Officer. The note attributed to the petitioner’s AO reportedly bore no date.
The order separately records the petitioner’s submission that the satisfaction note he received was the searched entity AO’s note, and that it was emailed to him on 14 September 2023, after a Section 153C notice dated 29 June 2022. Those timing details are the petitioner’s assertions as recorded by the court, not independent findings in the February 2025 order. The court also noted an asserted mismatch between the officer who issued the notice and the officer identified as the petitioner’s jurisdictional AO in the Revenue’s affidavit. Delhi High Court order, 10 February 2025.
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Why the assessment year matters in a Section 153C case
A related interim order dated 13 December 2023 concerned seven connected petitions covering assessment years (AYs) 2014-15 through 2020-21. In that order, the petitioner argued that the searched group’s 9 June 2022 satisfaction note identified material for FY 2015-16 (AY 2016-17) and FY 2016-17 (AY 2017-18), even though proceedings had been initiated for other assessment years too. The court said the issue required examination and stayed proceedings under the impugned notice pending further consideration. The year-specific description was the petitioner’s contention recorded in that order. Delhi High Court order, 13 December 2023.
The related legal principle is that the material must have a reasoned connection to the particular assessment year at issue. The Delhi High Court’s 16 May 2024 order in a separate petition reproduced this reasoning from Saksham Commodities Limited v. Income Tax Officer, Ward 22(1), Delhi & Anr.: “The mere existence of a power to assess or reassess the six AYs’ immediately preceding the AY corresponding to the year of search or the “relevant assessment year” would not justify a sweeping or indiscriminate invocation of Section 153C.” Delhi High Court order, 16 May 2024.
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A separate 2024 petition was quashed for AY 2018-19
The 16 May 2024 order was in Sanjeev Agarwal’s distinct W.P.(C) 15919/2023, concerning AY 2018-19. The court found that the 9 June 2022 satisfaction note referred to incriminating material for AYs 2016-17 and 2017-18, not AY 2018-19, and did not explain why that material could affect total income for AY 2018-19. Applying Saksham Commodities, the court allowed that petition and quashed the 29 June 2022 notice and consequential proceedings for that petitioner. This is a separate, year-specific disposition—not the outcome of the February 2025 petitions.
| Proceeding | Assessment-year issue | What the court did |
|---|---|---|
| W.P.(C) 15923/2023 and W.P.(C) 35/2024; order dated 10 February 2025 | Connected challenges; the order records discrepancies concerning satisfaction notes and officers | Directed production of the record and continued interim protection; did not quash the notice |
| Seven connected petitions; interim order dated 13 December 2023 | Petitioner argued material was identified for AYs 2016-17 and 2017-18 while proceedings covered other years | Stayed proceedings under the impugned notice pending further consideration |
| W.P.(C) 15919/2023; order dated 16 May 2024 | AY 2018-19; note identified material for AYs 2016-17 and 2017-18 | Quashed the notice and consequential proceedings for that petitioner |
What the orders mean for a Section 153C notice
These orders do not establish that a notice is invalid merely because a satisfaction note is undated or was provided to a taxpayer after the notice. The February 2025 court had not resolved those issues; it sought the record to examine them. The distinct May 2024 ruling addresses a different defect: the note did not identify material for AY 2018-19 or explain how the material could affect income for that year.
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For a challenge based on year relevance, the key question is whether the Assessing Officer’s satisfaction connects the received material to the particular assessment year or years in which Section 153C proceedings are initiated. A power to examine multiple years does not, by itself, justify applying the provision indiscriminately across them. The available order dated 10 February 2025 records interim directions only; check the official case docket for any later developments before relying on it as the current status of those petitions.
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