ITAT Delhi Quashes Assessment for Wrong Section Invocation After Section 153C Satisfaction

Asha Gutpa Vs DCIT (ITAT Delhi) In Asha Gupta vs DCIT, the Delhi ITAT examined whether the Assessing Officer (AO) could complete assessment for AY 2021–22 under Section 143(3) after recording satisfaction under Section 153C on 24.05.2022. A search under Section 132 was conducted on 26.10.2020 in another person’s case, and documents allegedly relating to the assessee were seized. The AO of the assessee recorded satisfaction on 24.05.2022 and issued notice under Section 143(2), completing assessment under Section 143(3) with an addition under Section 69A. The Tribunal held that as per the fi...