Recording of satisfaction mandatory prior to issuing notice u/s 153C & it should not be vague

Brief of the case:

ITAT Ahmedabad in the case of M/s. Parshwa Corporation Vs. DCIT observed the basic necessities & condition for issuing notice u/s 153 C and it was held that it is mandatory to follow the procedure prescribed under the section i.e.

(1) Satisfaction is to be recorded by the Assessing Officer of the persons searched;

(2) After recording the satisfaction, Assessing Officer of person searched should handover the seized material to the Assessing Officer of such other person;

(3) Thereafter, the Assess

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