ITAT Delhi Invalidates 153C Proceedings Because Satisfaction Note Lacked Income Link

Atoll Vyapaar (P) Ltd. Vs DCIT (ITAT Delhi) In Atoll Vyapaar (P) Ltd. Vs DCIT, the Income Tax Appellate Tribunal (ITAT), Delhi dealt with seven appeals concerning assessment years 2013–14 to 2020–21 arising from proceedings initiated under Section 153C read with Section 143(3) of the Income-tax Act, 1961. The primary issue raised by the assessee was the validity of these proceedings on the ground of improper satisfaction recorded by the Assessing Officer. The case originated from a search conducted on another entity, during which certain materials were allegedly found relating to the asses...