One Satisfaction Note for Seven Years Invalidates Section 153C: ITAT Pune

DCIT Vs Abhayraj Fattehraj Chordiya (ITAT Pune) No Asset ≥ ₹50 Lakh, No 10-Year Reach: One Satisfaction for Seven Years = No Jurisdiction: Pune ITAT Quashes 153C The Pune ITAT dismissed Revenue’s appeal and allowed Assessee’s cross-objection, quashing the entire assessment u/s 153C r.w.s. 143(3). The Tribunal held that the 153C proceedings were jurisdictionally invalid on multiple counts: (i) a single consolidated satisfaction note was recorded for seven AYs (2014-15 to 2020-21) instead of year-wise satisfaction, contrary to law; (ii) mechanical/common approval u/s 153D was granted for...