Consolidated Satisfaction Note Invalidates Search Assessment; 153C Proceedings Quashed

SRS Panchratan Diamonds Pvt. Ltd. Vs DCIT (ITAT Delhi) 153C Proceedings Quashed – Consolidated Satisfaction Note is Invalid; Tribunal Follows Delhi HC Saksham Commodities & Karnataka HC Sunil Kumar Sharma Tribunal first condoned 61 days’ delay & admitted both appeals. Core challenge was the validity of jurisdiction u/s 153C, where the AO recorded one consolidated satisfaction note for seven assessment years together (AYs 2011–12 to 2017–18), instead of preparing independent satisfaction notes for each year, & without showing how seized JBL-group digital data had any inc...