### Search Under Section 132 is Person-Centric; Ownership of Searched Premises Does Not Determine "Searched Person" Status Key Legal Principles: * Person-Centric Jurisdiction: A search under Section 132 is initiated against a person based on "reason to believe" (clauses a-c) and is not defined by the location searched under "reason to suspect" (clauses i-v). * Section 153A vs. 153C: Assessment under Section 153A applies only to the person named in the search warrant. Third parties whose premises are searched are "other persons" subject to Section 153C. * Satisfaction Notes: There is no statutory requirement to record separate satisfaction notes for each assessment year under Section 153C; a consolidated note is legally sufficient. * Precedential Hierarchy: A later Division Bench decision rendered *per incuriam* (ignoring prior binding coordinate bench precedents and statutory schemes) lacks precedential value. * Laches: Invoking writ jurisdiction after a four-year delay, specifically to stall assessments near the limitation deadline, constitutes laches.

A search under Section 132 of the Income Tax Act was initiated against Sri K. Narayan Raju.

During this process, a warrant was issued to search the residential premises of the Respondent (Sri C.R. Ram Mohan Raju) based on a "reason to suspect" that the primary target's documents were hidden there.

Based on materials seized from this location, the Assessing Officer (AO) recorded satisfaction under Section 153C and issued assessment notices for AYs 2011-12 to 2018-19.

The Respondent challenged these notices via a writ petition, arguing that since his premises were searched, he should be treated as a "searched person" under Section 153A rather than an "other person" under Section 153C.

The learned Single Judge quashed the notices.

The Revenue appealed this decision.

1. Whether a person whose premises are searched under a warrant issued in another person's name qualifies as a "searched person" under Section 153A or "any other person" under Section 153C.

2. Whether Section 153C requires the recording of a separate satisfaction note for each individual assessment year.

3. Whether the writ petition was liable for dismissal on the grounds of inordinate delay and laches.

The court applied Section 132 of the Income Tax Act, distinguishing between "reason to believe" against a person (clauses a-c) and "reason to suspect" regarding a premises (clauses i-v).

It relied on Section 153A for assessments of persons "searched" and Section 153C for "other persons".

C. Ramaiah Reddy v. CIT, establishing that search is person-centric.

PCIT v. Associated Mining Company, holding that premises identification is incidental to the target person.

CIT v. Calcutta Knitwears along with Super Malls (P) Ltd. v. CIT, which clarified that a consolidated satisfaction note is sufficient for Section 153C, especially when the AO for both parties is the same.

The Court reasoned that Section 132 is person-centric; the "searched person" is defined by the "reason to believe" recorded in the satisfaction note and the name on the warrant (Form 45), not the ownership of the searched location.

Upon perusal of the sealed satisfaction note, the Court found the warrant was issued in the name of K. Narayan Raju, while the Respondent’s address was merely the place of execution.

Consequently, the Respondent was correctly categorized as an "other person" under Section 153C.

Regarding the procedural challenge, the Court held that Section 153C does not explicitly mandate year-wise satisfaction notes; a consolidated note suffices if it indicates the documents belong to the "other person".

Finally, the Court noted that the Respondent approached the High Court with a four-and-a-half-year delay, just one month before the assessment deadline, which constituted fatal laches.

It held that a consolidated satisfaction note is legally valid.

The Division Bench set aside the Single Judge’s order, dismissed the original writ petition, and restored the notices issued under Section 153C for AYs 2011-12 to 2018-19.

The court emphasized that judicial discipline required following earlier Benches (Ramaiah Reddy and Associated Mining) over the later Sunil Kumar Sharma decision, which was deemed per incuriam for failing to consider the former.