Mukesh Chandra Agrawal Vs DCIT (ITAT Delhi)
Section 153C Assessment Invalid Because AO Failed to Record Proper Satisfaction; ITAT Delhi Cancels 153C Assessments Over Absence of ‘Bearing on Total Income’ Finding; Improper Satisfaction Note Vitiates Section 153C Proceedings; ITAT Delhi Says Section 153C Cannot Be Invoked Through Mechanical Recording of Satisfaction; Section 153C Proceedings Set Aside Because Satisfaction Note Lacked Mandatory Findings.
The appeals before the ITAT Delhi related to Assessment Years 2015-16, 2016-17, and 2020-21 and arose from orders passed by the Commissioner of Income Tax (Appeals), Delhi dated 30.01.2025 in proceedings under Section 153C of the Income Tax Act, 1961.
During the hearing, the Tribunal identified the primary legal issue as the validity of the Section 153C proceedings and assessments framed on 31.03.2023. The assessee challenged the proceedings on the ground that there was no valid satisfaction recorded by the lower authorities before initiating action under Section 153C.
The satisfaction note recorded by the Assessing Officer stated that a search and seizure operation had been conducted in the Alankit Group cases on 18.10.2019 and that certain documents related to the assessee were found during assessment proceedings under Section 153A. The seized documents included copies of sale deeds relating to residential properties at Agra, Delhi, and Mathura, allegedly connected with the assessee. The satisfaction note concluded that assessment proceedings were required to be initiated under Section 153C because warrants had been issued in the names of the searched parties belonging to the Alankit Group.
