153C Assessment Remanded for Failure to Examine Jurisdictional Satisfaction

Kakanatil Abdul Rahiman Siraj Mather Vs ACIT (Kerala High Court) 153C Satisfaction Is Jurisdictional — Kerala HC Sets Aside ITAT Order Remands Cases for Fresh Decision The Kerala High Court allowed a batch of appeals filed by the Assessee and remitted the matter back to the ITAT, Cochin Bench, holding that the Tribunal failed to properly examine the jurisdictional pre-condition of recording “satisfaction” u/s 153C of the Income-tax Act, 1961. The assessments for AYs 2010-11 to 2014-15 were framed u/s 153C based on documents seized during a search on a third party. The Assessee contended ...