U/s 153C Assessment Quashed – Defective Satisfaction Note & Invalid Jurisdiction

Vinay Homes Pvt. Ltd. Vs DCIT (ITAT Delhi) The ITAT Delhi allowed the assessee’s appeal and quashed the assessment framed u/s 153C r.w.s. 143(3) holding that the AO had assumed jurisdiction on the basis of an invalid satisfaction note. The Tribunal observed that the satisfaction note did not clearly identify seized material belonging to the assessee, failed to specify assessment-year-wise entries, and was based largely on appraisal report and external information rather than seized documents themselves. Further, a consolidated satisfaction note for multiple years and absence of clear linkage...