Section 153C satisfaction needs to be recorded even if AO of searched & other person is same

Palla Simhachalam (HUF) Vs ACIT (ITAT Visakhapatnam) AO of the searched person and the other person is one and the same, then also AO is required to record the satisfaction, as held by the various In the instant case, no such material has been brought before us by the ld. DR. In view of the above discussions, since the satisfaction was not recorded by the Assessing Officer before issue of notice U/s. 153C of the Act, we are of the considered view that the order passed by the Ld. CIT(A) U/s. 153C of the Act deserves to be set aside for all the impugned assessment years. It is ordered accordingl...