Satisfaction note should be recorded separately for assessee searched u/s 132

ACIT Vs Gracious Project Pvt. Ltd. (ITAT Delhi) The issue under consideration is that department has issued notice u/s 153C to the assessee on the basis of certain documents found from the premises of M/s Excel Infotech Pvt. Ltd. The Assessing officer wrote a satisfaction note, and held that these papers belong to the assessee. The assessee filed an appeal before the CIT(A). The CIT(A) allowed the appeal of the assessee. Hence now revenue filed the appeal against order of CIT(A). ITAT have perused all the relevant materials available on record including the submissions mentioned in assessment ...