ITAT Quashes Section 153C Order as Composite Satisfaction Note Lacked Year-Wise Bifurcation

Advertisement MPS Structure Private Limited Vs DCIT (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT), Delhi, allowed the assessee’s appeal by holding that the proceedings initiated under Section 153C of the Income Tax Act were invalid because the jurisdiction was assumed on the basis of a defective and composite satisfaction note that did not contain assessment year-wise bifurcation or correlate the seized material to the relevant assessment year. The case arose from a search conducted on 22 October 2016 in the Ashish Bhegwani Group. During the search, the Revenue alleged that th...