ITAT Delhi Invalidates 153A Assessments for Lack of 153C Satisfaction

Sanjeev Sharma Vs ACIT (ITAT Delhi) Third-Party Search Material Can’t Sustain 153A: ITAT Delhi Quashes Assessments for Want of 153C Satisfaction In this batch of five appeals, Sanjeev Sharma challenged assessments framed u/s 153A for AYs 2013-14 to 2017-18, wherein additions were made on the basis of a PowerPoint printout named “Kautilya Airbus Proposal” seized during search on Deepak Talwar Group. The core legal objection was that the seized documents belonged to a third party & could be used against the Assessee only after recording mandatory satisfaction u/s 153C by (i) the AO of ...