Non-recording of satisfaction by AO of searched person while issuing notice to other party makes notice illegal

ACIT Vs Gulshan Kumar Sethi (ITAT Delhi)

Conclusion: AO of the searched person had not rebutted the presumption that the seized documents  belonged to M/s. C Ltd but belonged to other person, i.e, assessee, therefore, issue of notice under section 153C on assessee was illegal.

Held: Search was conducted at the premises of M/s.C Ltd. and certain documents relating to assessee were seized. Based on the above documents, AO of assessee was requested to issue notice under section 153C to

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