Recording of satisfaction U/s. 153C when AO of Appellant & Searched Person is common

Pr. CIT Vs. Instronics Ltd. (Delhi High Court) In the present case, the ITAT overlooked the fact that the Satisfaction Note was in fact recorded by the assessing officer of the searched person who also happened to be the assessing officer for the assessee (the other person) as well. This is clear from the sentence in the Satisfaction Note which reads : “The undersigned is the jurisdictional assessing officer of these cases.” The assessing officer of the searched person has recorded the satisfaction that the seized documents belonged to the assessee. In similar circumstances in Satk...