Section 153C Assessments Void for Post-April 2021 Satisfaction Note: ITAT Delhi

Advertisement Parvesh Kumar Vs DCIT (ITAT Delhi) The Delhi ITAT considered appeals for AYs 2013-14 and 2014-15 challenging assessments framed under Section 153C read with Section 143(3) of the Income-tax Act, 1961. The assessee primarily questioned the validity of the jurisdiction assumed under Section 153C, contending that the satisfaction note was recorded after 1 April 2021, when the amended statutory framework no longer permitted initiation of proceedings under Section 153C in such circumstances. The assessee submitted that the Assessing Officer recorded the satisfaction note on 20.10.2...