153C Collapses at First Gate: RTI Exposes Non-Recording of Satisfaction by AO of Searched Person

Ratna Sagar Pvt. Ltd. Vs DCIT (ITAT Delhi) In these two appeals filed by Ratna Sagar Pvt. Ltd. for AYs 2018-19 & 2019-20, Tribunal examined a pure jurisdictional challenge to assessments framed u/s 153C. Assessee contended that no Satisfaction Note was recorded by the AO of the searched person, which is a mandatory jurisdictional pre-condition for triggering proceedings against “other person” u/s 153C. Assessee relied on an RTI reply dated 28.01.2025 where AO categorically stated that the satisfaction recorded by AO of searched person “is not available with this office”. Assessee t...