Recording of satisfaction by the AO is sine qua non before the issuance of notice under s 153C

ACIT v Vijay Traders (ITAT Indore) – The provisions of section 153C are analogous to section 158BD and, therefore, decisions rendered with reference to the provisions of section 158BD would apply with reference to the cases falling u/s 153C unless the context requires otherwise. The Apex Court in the case of Manish Maheshwari (supra) after considering the provisions of section 158BD held that: a. Satisfaction must be recorded by the Assessing Officer that any undisclosed income belongs to any person other than the person with respect to whom search was made u/s 132 of the Act b. The book...