Facts:

• The Income Tax Officer (Herein referred to as 'Revenue') was the Appellant.
• Vikram Sujitkumar Bhatia (Respondent) is an individual who filed a Return of Income for the Assessment Year 2012-13. & H.N. Safal Group (Assessee), where the income tax search was conducted at their various premises, were the respondents.
• On 04.09.2013, a search at H.N. Safal Group led to the seizure of documents related to the Respondent. Based on the documents, a proceeding under Section 153C of the Act 1961 was initiated against him.
• The Respondent initially filed a writ petition before the High Court of Gujarat challenging the notice under Section 153C issued on 08.02.2018. The High Court quashed the notices and assessment orders.
• Hence, the present appeal was filed before the Supreme Court.

Procedural Posture:

Assessing Officer’s holding

• Upon receiving the notice, the assessee replied on 01.05.2018 and submitted his income return. On 14.05.2018, the Assessing Officer shared satisfaction notes showing references to the Respondent in the seized Excel sheet.
• The Respondent objected, arguing the Excel sheet did not comply with the requirement of Section 153C of The Income Tax Act, 1961, and claimed the Assessing Officer’s satisfaction was insufficient and not independently recorded. (Paragraph 3.2)
• The Assessing Officer rejected the Respondent's objections, stating that the satisfaction was valid and the proceedings correctly initiated. (Paragraph 3.3)

Appeal to the High Court:

• The Respondent filed the case before the High Court of Gujarat, challenging the proceedings initiated under Section 153C of the Income Tax Act, 1961.
• Other individuals not directly searched but affected by similar notices under Section 153C also filed Civil Appeal No. 912 to 1026 OF 2022, challenging their assessments. Due to common issues, these cases were considered with this case.
• The High Court quashed the notices and set aside the assessment orders, ruling that the Finance Act, 2015 amendment to Section 153C could not be applied retrospectively to pre-2015 searches, as it affected substantive rights rather than procedural. (Paragraph 3.5)

Appeal to the Supreme Court:

• The Revenue appealed, challenging the High Court of Gujarat's interpretation of the retrospective application of the amended Section 153C of the Income Tax Act, 1961.

Main Issue:

• Does the amendment to Section 153C of the Income Tax Act, 1961 by the Finance Act, 2015, apply to searches conducted under Section 132 of the Act before 01.06.2015, the date of the amendment? (Paragraph 2)