Assessment U/s. 153C invalid if No satisfaction recorded in case of other person, i.e. assessee

PCIT Vs N.S. Software (Firm) (Delhi High Court) It is now a settled proposition of law that even if AO for the person from whose premises documents were seized is the same as the AO for the person to whom  document belonged, separate satisfaction notes must be recorded. In the instant case, the AO’s note nowhere reflected whether any document seized, on application of his mind, disclosed that it belonged to the assessee, and if so, its prima facie nature. Therefore, proceedings under section 153C were void ab initio. In the present case, therefore, the failure of the AO to record a speci...