No Satisfaction Note, No Section 153C Assessment

Rajan Verma Vs DCIT (ITAT Delhi) No Satisfaction Note, No 153C Assessment: Delhi ITAT Quashes Orders for AYs 2018-19 to 2020-21 Delhi ITAT ‘E’ Bench in Rajan Verma vs DCIT, Central Circle-30, New Delhi (ITA Nos.966, 967 & 968/Del/2025; AYs 2018-19, 2019-20 & 2020-21; order dated 23-12-2025) quashed the assessments framed u/s 153C, holding that the mandatory satisfaction note was not recorded by the AO who ultimately framed the assessments, vitiating the proceedings at the threshold. Revenue contended that since the AO of the “searched person” and the “other person” was the ...