Order set aside as satisfaction note was recorded without application of mind: ITAT Delhi

Rajiv Agarwal Vs ACIT (ITAT Delhi) ITAT Delhi held that orders passed based on illegal assumption of jurisdiction on the basis of satisfaction note which was recorded without application of mind and quite in a mechanical manner is liable to be set aside. Accordingly, addition deleted. Facts- A search and seizure action u/s 132(1) of the Act was carried out on 28.06.2016 in Paras Mal Lodha Group of cases. The assessment orders u/s 153A of the Act were passed in the case of Sh. Paras Mal Lodha, an alleged Hawala Operator in December 2019. A satisfaction note was recorded by the AO of the searche...