Section 153C Assessment Set Aside as AO Failed to Record Year-Wise Satisfaction: ITAT Delhi

Parveen Garg Vs DCIT (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT), Delhi, allowed the assessee’s appeal for Assessment Year (AY) 2020-21 after holding that the assessment initiated under Section 153C of the Income-tax Act, 1961 was invalid because it was based on a consolidated satisfaction note covering multiple assessment years instead of a year-specific satisfaction note. At the outset, the Tribunal condoned a delay of 24 days in filing the appeal after accepting the assessee’s explanation that the delay was neither deliberate nor intentional and had occurred because th...