Consolidated Satisfaction Note for Multiple Years Held Invalid – ITAT Quashes Entire U/s 153C Assessments

Ankit Agarwal & Sons Vs DCIT (ITAT Delhi) The Delhi ITAT quashed assessments framed u/s 153C against multiple assessees including Ankit Agarwal, Alok Agarwal and Jagmohan Kejriwal after holding that the Assessing Officer recorded a single consolidated satisfaction note for several assessment years without identifying year-wise incriminating material or bifurcating alleged additions pertaining to each year. The Tribunal noted that consolidated satisfaction notes were recorded covering broad blocks of years from AY 2010-11/2014-15 up to AY 2020-21, and assessments were framed solely on the b...