Section 153C Assessment Quashed for Defective Consolidated Satisfaction Note: ITAT Delhi

Sunwhite Realty Private Limited Vs DCIT (ITAT Delhi) The appeal arose from an assessment framed under Section 153C read with Section 143(3) of the Income-tax Act, 1961 for Assessment Year 2016-17. The assessee challenged the jurisdiction assumed under Section 153C, contending that the assessment had been initiated on the basis of a consolidated satisfaction note. The assessee relied upon an earlier decision of a Coordinate Bench involving an identical satisfaction note arising from the same search proceedings, where such satisfaction had been held to be legally defective. The Revenue contended...