Assessment U/s. 153C liable to be quashed if No satisfaction recorded by AO

Zaidun Leeng Sdn Bhd Artefact Projects Ltd. (JV) Vs DCIT (ITAT Nagpur)

It is evident that recording of requisite satisfaction in the case of a searched party is a sine qua non for assuming jurisdiction for the issue of notice u/s 153C even if the AO of the searched person and the assessee are same. It is abundantly clear from the records in the case of the searched person that there is no requisite satisfaction granting the AO jurisdiction for issuing notice to the assessee u/s 153C of the T. Act. No satisfact

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