Section 153C Assessment Quashed Due to Consolidated Satisfaction Note Error: ITAT Pune

Ramdas Chabaji Dhankude Vs ACIT (ITAT Pune) Core Issue:– The central issue involved is whether the assumption of jurisdiction under section 153C of the Income Tax Act is valid where the Assessing Officer records a single consolidated satisfaction note for multiple assessment years, or whether the law mandates separate and year-specific satisfaction for each assessment year, failing which the entire proceedings become void ab initio. Facts:- The assessee, an individual, originally filed return declaring income from partnership firm and other sources. A search under section 132 was conduct...