Section 153C Assessment Quashed Because Consolidated Satisfaction Note Lacked Year-Wise Incriminating Material

Seema Agarwal Vs DCIT (ITAT Delhi) In the present case, search and seizure action under section 132 was conducted in the case of a third party, during which certain documents were allegedly found and seized which were stated to relate to the assessee. Based on the seized material, the Assessing Officer of the searched person recorded a satisfaction note dated 15.03.2022 under section 153C stating that the seized documents belonged to or pertained to the assessee and had a bearing on determination of her income. However, instead of recording separate satisfaction for each assessment year, the A...