The Delhi High Court did not quash the Section 153C notice in its 10 February 2025 order. It directed the Revenue to produce the relevant record and continued interim protection while it examined discrepancies concerning satisfaction notes and the officers involved. A separate May 2024 order did quash a notice for assessment year (AY) 2018-19, but that was a different petition and a year-specific issue.
What the Delhi High Court ordered in February 2025
In its 10 February 2025 order, a bench of Justices Yashwant Varma and Harish Vaidyanathan Shankar considered W.P.(C) 15923/2023, filed by Sanjeev Agarwal, and connected W.P.(C) 35/2024, filed by Sudhir Agarwal. The court said the issues raised warranted an explanation, directed the Revenue to produce the relevant record at the next hearing, and continued interim protection.
As an Amazon Associate I earn from qualifying purchases.
That was a procedural direction, not a final ruling on the notice’s validity. The order did not quash the notice or finally decide whether the Section 153C proceedings were lawful.
Do these 3 things before closing this tab:
1Fix the driver behind crashes, sound loss and screen glitches2Clear out junk files and repair common Windows errors3Scan for outdated or missing drivers - takes under a minuteWhat the order says about the satisfaction notes
According to details recorded from the respondents’ additional affidavit, the searched entity’s jurisdictional Assessing Officer (AO) 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 affidavit said the material was transmitted to the petitioner’s jurisdictional AO; the note attributed to that AO reportedly bore no date.
#1 Best Overall
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 the Section 153C notice dated 29 June 2022. This is the petitioner’s account, not an independent finding by the court. 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.
Why the assessment year matters under Section 153C
Section 153C proceedings concern material found in a search that is said to relate to a person other than the person searched. The legal issue highlighted in the related Delhi High Court orders is not simply whether the department may examine multiple years; it is whether the required satisfaction connects the material to the particular assessment year or years in which action is taken.
Rank #2
In a separate order dated 16 May 2024, the court reproduced the reasoning in Saksham Commodities Limited v. Income Tax Officer, Ward 22(1), Delhi & Anr. that the AO must form an opinion that the received material is likely to affect total income for the specific year or years. The reproduced passage states: “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.”
PC Slower Than It Used to Be?
A free scan shows the junk files, broken settings and background clutter dragging Windows down - then fixes them in one click.Free scan · Windows 10 & 11Outdated Drivers Are Slowing You Down
One free scan finds every outdated or missing driver and matches the right update for your exact hardware.Free scan · exact hardware matchHow the connected orders differ
| Proceeding and order | Assessment-year issue | What the court did |
| W.P.(C) 15923/2023 and W.P.(C) 35/2024; 10 February 2025 | The affidavit described a 9 June 2022 note and an undated note attributed to the petitioner’s AO. The court recorded discrepancies but did not finally resolve them. | Directed production of the record and continued interim protection; did not quash the notice. |
| Seven connected petitions; interim order of 13 December 2023 | The petitioner argued that the searched group’s 9 June 2022 note identified material for FY 2015-16 (AY 2016-17) and FY 2016-17 (AY 2017-18), while proceedings covered other assessment years too. | Recorded that the issue required examination and stayed proceedings under the impugned notice pending further consideration. |
| Sanjeev Agarwal’s W.P.(C) 15919/2023; 16 May 2024 | AY 2018-19. The court found that the note referred to material for AYs 2016-17 and 2017-18, not AY 2018-19, and did not explain how it could affect income for AY 2018-19. | Allowed that petition and quashed the 29 June 2022 notice and consequential proceedings for that petitioner. |
The year mapping in the December 2023 proceeding was recorded as the petitioner’s argument, not as a final finding about every notice in the connected cases. The May 2024 quashing, by contrast, was a distinct disposition concerning AY 2018-19.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What this means for a Section 153C notice
These orders do not establish that every notice covering years not named in a satisfaction note is automatically invalid. They show why the record and year-specific link matter: the AO’s satisfaction must address whether the seized material may affect income for the particular year in question. In February 2025, the court required the Revenue to produce the record before deciding the challenge; in the separate May 2024 petition, it found the year-specific connection missing for AY 2018-19 and quashed that notice.
The February order establishes only the directions made on 10 February 2025. It does not state the eventual outcome of those proceedings.
Quick Recap
Product prices and availability are accurate as of the date/time indicated and are subject to change. Any price and availability information displayed on Amazon at the time of purchase will apply.
What’s actually slowing this PC down?
Pick the symptom - the matching free tool is one click away.
