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Income Tax

Section 153C – Mere use or mention of word “satisfaction” or the words “I am satisfied” in order or note is not sufficient

Case Law Details

Case Name
Asstt. CIT Vs Pepsi Foods Pvt. Ltd. (Delhi High Court)
Date of Judgement/Order
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On a plain reading of Section 153C, it is evident that the Assessing Officer of the searched person must be “satisfied” that inter alia any document seized or requisitioned “belongs to” a person other than the searched person. It is only then that the Assessing Officer of the searched person can handover such document to the Assessing Officer having jurisdiction over such other person (other than the searched person). Furthermore, it is only after such handing over that the Assessing Officer of such other person can issue a notice to that person and assess or re-assess his income in ac...
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