Invalid Jurisdiction Under Section 153C Due to Vague Satisfaction Note for Multiple Years

Aashrya Developers Private Limited Vs ACIT (ITAT Delhi) In Aashrya Developers Private Limited Vs ACIT, the appeals were filed against orders passed under Section 250(6) of the Income Tax Act, 1961 for Assessment Years 2011–12, 2012–13, 2013–14, and 2015–16. The primary issue concerned the validity of jurisdiction assumed under Section 153C following a search conducted on 21.07.2016 in the M3M Group. A satisfaction note was recorded on 25.09.2018 alleging that seized material (Annexure A-3) contained information relating to the assessee. For AY 2011–12, the assessee contended that the...