ITAT Quashes Section 153C Assessment as Satisfaction Note Lacked Mandatory Finding

Deepak Builders and Engineers India Ltd. Vs DCIT (ITAT Delhi) The cross appeals before the Income Tax Appellate Tribunal (ITAT), Delhi, arose from the order of the Commissioner of Income Tax (Appeals)-30 dated 20 December 2024 for the assessment year 2020-21, relating to proceedings initiated under Section 153C read with Section 143(3) of the Income-tax Act. The Tribunal first addressed the legal issue concerning the validity of the proceedings initiated under Section 153C and the assessment framed on 26 March 2023. It considered whether the proceedings were supported by a legally valid satisf...