Recording of satisfaction by AO of “person searched” is a condition precedent for AO of “other person” to acquire jurisdiction

Adarsh Kumar Vs. Dy. CIT (ITAT Delhi)

Recording of satisfaction by AO of “person searched” is a condition precedent for AO of “other person” to acquire jurisdiction and unless jurisdictional condition is satisfied, there can be no question of making assessment or reassessment in the case of such other person.

Settled position of law is that so far as the assessing officer of the “searched person” is concerned, he has to only record a satisfaction that documents seized “belong” or “belongs to” other person. The assessi

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