Where no satisfaction was recorded by AO at the time of search, revenue cannot attain jurisdiction over other person

Brief of the case:

In the case of ACIT Vs. Shivaansh Advertising & Publications Pvt. Ltd. Delhi Bench of ITAT observed the requirements of section 153C provides for taking recourse to assessment in respect of any other person and held the conditions precedent are :

(i) Satisfaction must be recorded by the AO that any undisclosed income belongs to any person, other than the person with respect to whom search was made under s. 132;

(ii) The books of account or other documents or assets seized or requisitioned had been handed over to the AO having jurisdiction over such other person; and

(iii) The AO has proceeded under s. 153C against such other person.

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