No assessment u/s 153C as satisfaction note was not recorded for relevant search assessment years

K.R. Chawla Consulting Pvt Ltd Vs DCIT (ITAT Delhi)

Conclusion: Since the satisfaction recorded by AO of assessee was only on 18.01.2021 making the search year AY 2021-22, therefore, the assessment proceedings initiated u/s 153C in AYs 2011-12, 2012-13 & 2013-14 were outside the jurisdiction. Accordingly, the assessment of these assessment years were set aside as void ab initio.

Held: Assessee appealed after a search was conducted on the premises of Harvansh Chawla, a third party, in 2016. During the search, certain documents be

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