Recording of satisfaction note before initiation of proceedings u/s. 153C is invalid satisfaction

Smt. Geetanjali Bhayana Vs DCIT (ITAT Delhi)

ITAT Delhi held that satisfaction note recorded before initiation of the proceedings u/s 153C of the Income Tax Act is not a valid satisfaction. Accordingly, proceedings u/s. 153C of the Income Tax Act is quashed since based on invalid satisfaction.

Facts- A search and seizure operation was carried out at various premises of Shri Kuldeep Bishnoi Group and its associates on 23.07.2019. Various documents/books of accounts etc. were found and seized and statements of various persons were recorded. It was found that

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