Section 153C Proceedings Invalid if AO Failed to Record Proper Satisfaction: ITAT Delhi

Narender Nath Vs DCIT (ITAT Delhi) The ITAT Delhi allowed the assessee’s appeal for Assessment Year 2021-22 and quashed the assessment framed under Sections 153C read with 143(3) of the Income Tax Act. The appeal arose against the order of the CIT(A)-23, Delhi dated 28.07.2025. The primary issue before the Tribunal was whether the satisfaction recorded by the Assessing Officer under Section 153C was legally valid for initiating proceedings against the assessee, who was a third party to the search proceedings. A search operation had been conducted on 23.03.2021 in the case of M/s KK Spun Grou...