Non-recording of satisfaction by AO of searched person while issuing notice to other party makes notice illegal

ACIT Vs Gulshan Kumar Sethi (ITAT Delhi) Conclusion: AO of the searched person had not rebutted the presumption that the seized documents  belonged to M/s. C Ltd but belonged to other person, i.e, assessee, therefore, issue of notice under section 153C on assessee was illegal. Held: Search was conducted at the premises of M/s.C Ltd. and certain documents relating to assessee were seized. Based on the above documents, AO of assessee was requested to issue notice under section 153C to assessee. Accordingly, AO initiated proceedings under section 153C r.w.s. 153A  and made addition. Assessee ch...