The Punjab & Haryana High Court upheld Section 153C notices, confirming that the satisfaction note was not belated and limitations objections must first be raised before the AO.
P&H HC Upholds Validity of Section 153C Notices
The Punjab and Haryana High Court has validated the issuance of Section 153C notices, determining that the satisfaction note issued by the authorities was timely and met the legal requirements. The court also reiterated that any objections related to limitations should be raised directly before the Assessing Officer (AO) prior to being contested in court.
This ruling emphasizes procedural adherence regarding the issuance of notices and sets a clear guideline on raising limitations objections during assessment proceedings. It underscores the importance of following proper channels, thereby preserving the efficiency of tax administration.
Tax professionals must be aware of this ruling which emphasizes procedural compliance and the proper framing of objections in assessment matters, aligning with judicial expectations for contesting tax notices.
Citations
- P&H HC (2026) TaxGuru 05


