Reassessment based on material found by AO of searched person is untenable in absence of satisfaction note u/s. 153C

Paras Chandreshbhai Koticha Vs ITO (Gujarat High Court)

Gujarat High Court held that reopening of assessment u/s. 147 of the Income Tax Act solely on the basis of material found by AO of searched person without satisfaction note as prescribed under section 153C is untenable in law.

Facts- The present group of petitions arise from the proceedings/ notices issued to the respective petitioners under Section 148 of the Income-tax Act, 1961, reopening the assessment under Section 147 of the Act. The issue raised in the instant writ petitions arises prior to the

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