ITAT Delhi Quashes Section 153C Assessments as Satisfaction Note Lacked Mandatory Finding

Shayam Gupta Vs DCIT (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT), Delhi, allowed the assessee’s appeals for Assessment Years (AYs) 2018-19 to 2021-22 after holding that the proceedings initiated under Section 153C of the Income-tax Act, 1961 were invalid because the mandatory satisfaction recorded by the Assessing Officer (AO) did not state that the seized material had a bearing on the determination of the assessee’s total income. The appeals arose from assessment orders passed under Section 153C read with Section 143(3), which had been upheld by the Commissioner of Income Tax (A...