Recording of satisfaction u/s 153C is mandatory even if searched person & assessee are under common jurisdiction

Brief of the Case Delhi High Court held In the case of Principle CIT vs. Nikki Drugs & Chemicals Pvt. Ltd. that the Allahabad High Court in the case of Commissioner of Income Tax v. Gopi Apartments: (2014) 365 ITR 411 (All.) has held that even in cases where the assessing officer of the person searched and the assessee who is sought to be assessed under Section 153C is the same, the assessing officer is required to record his satisfaction that the assets/ documents seized belong to a person other than the searched person. Thus, it is necessary for the assessing officer of the searched per...