Commissioner Of Income Tax-Iii vs Singhad Technical Education Society

The Supreme Court held that the proceedings initiated under Section 153C of the Income Tax Act, 1961, require a Satisfaction Note to be recorded by the Assessing Officer (AO) of the person searched before using seized documents against a third party. The Court upheld the High Court's decision to quash the notice issued under Section 153C, stating that the AO failed to establish the genuineness of the trust and did not comply with the procedural requirements. Consequently, the appeals filed by the Revenue were dismissed, affirming the ITAT's ruling.