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Consolidated Satisfaction Note for Multiple Years Held Invalid – ITAT Quashes Entire U/s 153C Assessments
Case Law Details
- Case Name
- Ankit Agarwal & Sons Vs DCIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2017-18
- Courts
- All ITAT, ITAT Delhi
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Ankit Agarwal & Sons Vs DCIT (ITAT Delhi)
The Delhi ITAT quashed assessments framed u/s 153C against multiple assessees including Ankit Agarwal, Alok Agarwal and Jagmohan Kejriwal after holding that the Assessing Officer recorded a single consolidated satisfaction note for several assessment years without identifying year-wise incriminating material or bifurcating alleged additions pertaining to each year. The Tribunal noted that consolidated satisfaction notes were recorded covering broad blocks of years from AY 2010-11/2014-15 up to AY 2020-21, and assessments were frame...
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