Carbon-Copy Satisfaction Note Fatal: 153C Satisfaction Mechanical Proceedings Held Void Ab Initio

Shokeen Construction Co. Vs DCIT (ITAT Delhi) Assessee filed returns for AYs 2018-19 to 2020-21. A search u/s 132 was conducted on 26.10.2020 in the cases of Sanjay Jain & Mehta Group. Two tally books were found at Sanjay Jain’s premises. AO of searched person recorded satisfaction on 16.08.2022 alleging that certain entries pertained to Assessee. AO of Assessee issued notice u/s 153C on 24.08.2022 & completed assessments u/s 153C r.w.s.143(3), making addition on alleged bogus purchases of Rs.20,34,531/- (AY 2018-19). CIT(A) upheld initiation of 153C proceedings & confirmed addit...