Common Satisfaction Note for Multiple AYs Invalid U/s 153C: ITAT Bangalore

Pramod Subbiahnapalya Venkatpathi Vs DCIT (ITAT Bangalore) Common Satisfaction Note for Multiple Years Invalid – Separate Satisfaction U/s 153C Required for Each AY: ITAT Bangalore The ITAT Bangalore held that recording a single consolidated satisfaction note for multiple assessment years is invalid for initiating proceedings u/s 153C, and separate satisfaction must be recorded for each assessment year based on incriminating material. In the present case, a search was conducted in the premises of a charitable trust and related persons. Based on seized material, the AO issued notices u/s ...