ITAT Strikes Down 153C Order for Copy-Paste Satisfaction Without Application of Mind

Revelation Unique Retail And Marketing Pvt. Ltd. Vs ACIT (ITAT Delhi)

Mechanical Satisfaction Note, No Incriminating Material: ITAT Delhi Strikes Down Entire 153C Assessment

Assessee challenged reassessment u/s 153C arising from search in the case of Shri Pranjil Batra on 17.08.2020. Assessee had not filed return for AY 2019-20. AO issued notice u/s 153C r.w.s 153A on 14.01.2022 after recording a “satisfaction note”. Assessee did not respond to multiple notices, & AO, relying on alleged seized material, made additions of ₹17,70,12,272 u/s 69A r.w.s

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