Addition based on seized document related to year different than notice issued U/s. 153C not valid

Pr. CIT Vs Shrim Investment Solutions (P) Ltd. (Delhi High Court) A perusal of the aforesaid satisfaction note recorded by the assessing officer reveals that the satisfaction note pertains to assessment year 2004-05 to assessment year 2009-10. It is undisputed that the documents referred to by the assessing officer pertain to assessment year 2010-11 and not to assessment year 2004-05 to 2009-10. It is also undisputed that the impugned transactions are duly recorded in the regular books of accounts pertaining to assessment year 2010-11. We agree with the contentions of the learned AR that altho...