Delhi HC Quashes Section 153C Notices Due to Defective Satisfaction Note

Kishore Kumar Sharma Vs ACIT (Delhi High Court) The Delhi High Court, in the case of Kishore Kumar Sharma Vs. ACIT, quashed notices issued under Section 153C of the Income Tax Act, 1961, spanning seven Assessment Years (AYs) from 2014-15 to 2020-21, due to a defective ‘Satisfaction Note.’ The core issue was the failure of the petitioner’s jurisdictional Assessing Officer (AO) to record the requisite satisfaction that the material received from a search conducted on a third party had a bearing on the petitioner’s total income for the years in question. The court noted that t...