Consolidated satisfaction note u/s. 153C for different assessment year vitiates entire proceedings

ACIT Vs Subhash Jivraj Jain (ITAT Pune) ITAT Pune held that satisfaction note is required to be recorded u/s 153C for each assessment year and a consolidated satisfaction note recorded for different assessment years would vitiate the entire assessment proceedings. Accordingly, appeal of revenue dismissed. Facts- A search action u/s 132 of the Act was carried out in the Yuvraj Dhamale group of cases on 26.09.2017. During the course of search action, various incriminating documents were found and seized which also include certain documents which contain information relating to the assessee. In r...