Section 147: Manner of recording satisfaction not prescribed

Shri Sushil Kumar Golecha Vs ACIT (ITAT Indore)

The law is well settled where the issue of jurisdiction of assessing authority is concerned, if the jurisdiction assumed is not in accordance with law, then it cannot be cured or ignored under the provisions of section 292B of the Act. In our considered view, the assumption of jurisdiction would begin from the recording of satisfaction by the A.O. that certain income has escaped assessment pertaining to a particular assessment year. Admittedly, the assessee has not challenged the validity of notice u/s 148

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