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Common Satisfaction Note for Multiple AYs Invalid U/s 153C: ITAT Bangalore
Case Law Details
- Case Name
- Pramod Subbiahnapalya Venkatpathi Vs DCIT (ITAT Bangalore)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2015-16
- Courts
- All ITAT, ITAT Bangalore
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Pramod Subbiahnapalya Venkatpathi Vs DCIT (ITAT Bangalore)
Common Satisfaction Note for Multiple Years Invalid – Separate Satisfaction U/s 153C Required for Each AY: ITAT Bangalore
The ITAT Bangalore held that recording a single consolidated satisfaction note for multiple assessment years is invalid for initiating proceedings u/s 153C, and separate satisfaction must be recorded for each assessment year based on incriminating material.
In the present case, a search was conducted in the premises of a charitable trust and related persons. Based on seized material, the AO is...
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