Section 153C Notice Invalid for 22-Month Delay in Recording Satisfaction

Farooqi Gulam Samdani Vs DCIT (ITAT Heyderabad) ITAT Hyderabad Quashes 153C Assessment for 22-Month Delay in Recording Satisfaction; ₹1.50 Cr Cash Addition Rendered Academic The Hyderabad ‘B’ Bench of the ITAT, in Shri Farooqi Gulam Samdani vs. DCIT, Central Circle-1(3), Hyderabad (ITA No. 814/Hyd/2025, AY 2019-20), vide order dated 24-12-2025, quashed the assessment framed u/s 153C on the ground of inordinate delay in recording satisfaction and issuing notice. A search u/s 132 was conducted on 22-11-2018 in the case of a third party, during which an agreement of sale allegedly showing c...