ITAT Quashes Section 153C Assessments as Consolidated Satisfaction Note for Multiple Years Was Invalid

Advertisement Rakesh Trisal Vs DCIT (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT), Delhi, allowed the assessee’s appeals for Assessment Years (AYs) 2016-17 and 2019-20 after holding that the assumption of jurisdiction under Section 153C of the Income-tax Act, 1961 was invalid because it was based on a consolidated satisfaction note covering multiple assessment years. The appeals arose from assessment orders passed under Sections 153C read with 143(3), whereby certain additions had been made. The Commissioner of Income Tax (Appeals) [CIT(A)] dismissed the assessee’s appea...